Kory & Allison Read’s Response for Human Rights Part 2

The document copied below is a mess…. I still haven’t read it all as it goes off on items not important.

Still, Once again, where is the evidence of violations of Human Rights against them?


The Applicants would now like to take this opportunity to reply to the

The Applicants would like to first discuss the current situation of the HRTO Complaints filed by the Applicants.

It should be noted that the Divisional Court appeal only involves Allison Read and none of the other members of the family. The appeal filed with Divisional Court was filed only on behalf of Allison Read and she is the only individual named by the 3 Respondents on any of the N5 for the September 26, 2017 LTB hearing. The facts of the appeal are based on the many bias and serious errors of law made by the Social Justice Tribunals Ontario Member Kevin Lundy against Allison Read and none of the other family members.

Based on these grounds, there can be no issue relating to the 3 remaining family members as legally they are not part of the appeal in Divisional Court, nor were they legally part of the LTB hearing on September 26, 2017 in any legal capacity.

Therefore at a minimum, the HRTO complaints filed by father, daughter and son can move forward freely as there are no issues of conflicts under the Human Rights Code.

If the HRTO still figures that this is a potential issue, the mother being the guardian on behalf of the daughter and son in regards to their HRTO complaints.

Both parents at this time would like to withdraw their consents for the HRTO request to consolidate all 4 complaints against the 3 Respondents.

Both parents at this time would like to request that the children are placed under the father’s guardianship for the purpose of the HRTO complaints, so at least the 3 other family members can precede forward while the mothers is deferred and/or dismissed.

1

STELLA REDDY PRESENTS LTB HEARING AND DIVISIONAL COURT DOCUMENTS

( EXHIBIT # 01 ) – On June 14, 2018 the now alleged former Alto Properties Inc. Property Manager Stella Reddy filed her own HRTO complaint against the Applicants – file number 2018–32928–

The now alleged former Alto Properties Inc. Property Manager Stella Reddy presented 22 different pieces of documentation to the HRTO as part of her own complaint against the Applicants.

( EXHIBIT # 02 ) Order by the LTB for an applicant filed by the Applicants for a hearing on October 31, 2017 ( 1 page ) ( EXHIBIT # 03 ) N5 dated September 05, 2017 ( 4 pages ) *

( EXHIBIT # 04 ) An email from the Applicants to alleged former Alto Properties Inc. Property Manager Stella Reddy dated August 30, 2017 ( 3 pages ) *

( EXHIBIT # 05 ) A copy of a Notice of Entry dated Friday September 01, 2017 ( 1 page ) *

( EXHIBIT # 06 ) An email from the Applicants to alleged former Alto Properties Inc. Property Manager Stella Reddy dated August 25, 2017 ( 1 page ) *

( EXHIBIT # 07 ) An email from the Applicants to alleged former Alto Properties Inc. Property Manager Stella Reddy dated August 25, 2017 ( 1 page ) *

( EXHIBIT # 08 ) N5 dated August 25, 2017 ( 4 pages ) *

( EXHIBIT # 09 ) A copy of a Notice of Entry dated Friday August 24, 2017 ( 1 page ) *

( EXHIBIT # 10 ) A copy of a Maintenance Request by the Applicants dated August 21, 2017 ( 1 page ) * ( EXHIBIT # 11 ) A letter by the Applicants to the 3 Respondents dated August 31, 2016 ( 7 pages ) *

( EXHIBIT # 12 ) A letter by the Applicants to the 3 Respondents dated October 17, 2016 ( 2 pages ) * ( EXHIBIT # 13 ) Applicants Notice Of Appeal filed with Divisional Court ( 9 pages ) *

( EXHIBIT # 14 ) Applicants Certificate Respecting Evidence filed with Divisional Court ( 3 pages ) *

( EXHIBIT # 15 ) Complaint to End a Tenancy and Evict a Tenant – FORM 2 dated September 5th 2017 ( 14 pages ) * ( EXHIBIT # 16 ) Applicants complaint filed with the LTB for a hearing on October 31, 2017 ( 15 pages ) *

( EXHIBIT # 17 ) Print out of 859kennedyroad.com website ( 2 pages )

( EXHIBIT # 18) Illegal eviction order created by Social Justice Tribunals Ontario Member Kevin Lundy dated October 03, 2017 ( 3 pages ) *

( EXHIBIT # 19 ) Front page of Applicants complaint filed with the LTB for a hearing on October 31, 2017  ( 1 page ) ( EXHIBIT # 20 ) Front page of the 3 Respondents complaint filed with the LTB for a hearing on September 26, 2017

( 1 page ) *

( EXHIBIT # 21 ) A email by the Applicants to the 3 Respondents dated July 04, 2018 ( 7 pages ) ( EXHIBIT # 22 ) A copy of the Applicants Facebook survey ( 8 pages )

( EXHIBIT # 23 ) A complete copy of the Applicants HRTO Statement of Facts dated June 04, 2018 ( 107 page )

* Was introduced and accepted by the LTB and Divisional Court and is on file.

( EXHIBITS #02 through #23 ) Of the 22 different pieces of documentation given to the HRTO by the now alleged former Alto Properties Inc. Property Manager Stella Reddy.

16 pieces or 73% of her own documentation had already been filed by the Applicants at the LTB hearing and/or with the Divisional Court. This means that almost 3/4 of her own documentation was already part of another legal proceeding.

( EXHIBIT # 24 ) Reviewing the now alleged former Alto Properties Inc. Property Manager Stella Reddy complaint which was filed against the Applicants – Under Part 14. [ C ] Other Proceeding – Other Proceeding – In Progress ( Are you asking the Tribunal to defer ( postpone ) your Complaint until the other proceeding is completed? ) she checks off the box [ NO ]

So at the time the alleged former Alto Properties Inc. Property Manager Stella Reddy was filing her own HRTO complaint against the Applicants. She made it very certain that she did not wish to have her complaint deferred despite knowing that there could have been issues of;

  • Over Lapping Evidence
  • Ongoing Proceedings
  • Avoiding Inconsistent Findings Of Facts Of Law
  • 1 ( one ) Year Time Limit
  • Absolute Privilege
  • Issues Appropriately Dealt With
  • Abuse Of Process
  • No Reasonable Prospect Of Success

In spite of these potential above issues, that the alleged former Alto Properties Inc. Property Manager Stella Reddy was very comfortable with the idea and hopeful of her own HRTO complaint going forward against the Applicants.

( EXHIBIT # 23 ) In fact the now alleged former Alto Properties Inc. Property Manager Stella Reddy even handed in the Applicants own HRTO Statement of Facts as part of her own complaint against them.

It appears that the alleged former Alto Properties Inc. Property Manager Stella Reddy was not at all troubled by all the issues of her racially charged language, prejudice slurs and her own racially motivated actions of harassment, discriminating and acting in a reprisal manner being stated against her as she presented it as evidence in her own complaint against the Applicants.

It appears that the alleged former Alto Properties Inc. Property Manager Stella Reddy thought that all these above issues were a “ normal human reaction ” and that it would help her win her HRTO complaint against the Applicants.

Let us note that she did this willing and without any threats of reprisal, violence, repercussions or intimidation in an attempt to prove that she was not racist or prejudice.

It also seems pretty astonishing how that the now alleged former Alto Properties Inc. Property Manager Stella Reddy was okay with the idea of hand picking through the documentation that was filed by the Applicant at LTB hearing, Divisional Courts and the HRTO in her attempt to get a favorable ruling in her own HRTO complaint against the Applicants.

But now suddenly takes issue with these same documents being presented against her. The now alleged former Alto Properties Inc. Property Manager Stella Reddy takes a 180 degree about turn now requesting that a defer and/or dismissal against the Applicants is needed based on the same documents she presented.

2

STELLA REDDY CONFIRMS SHE KNOWS OF DIVISIONAL COURT APPEAL

( EXHIBITS # 02 through #23 ) So let us recap. Of the 22 different pieces of documentation given to the HRTO by the now alleged former Alto Properties Inc. Property Manager Stella Reddy. 16 pieces or 73% of her own documentation had already been filed by the Applicants at the LTB hearing and/or with the Divisional Court. This means that almost 3/4 of her own documentation presented to the HRTO was already part of another legal proceeding.

So on June 14, 2018 a total of 232 days had already passed since the Applicants filed for the appeal in Divisional Court.

Meaning, the now alleged former Alto Properties Inc. Property Manager Stella Reddy willing filed her own HRTO complaint against the Applicants using their LTB hearing and the Divisional Court documents for 73% of her own documentation in her complaint against them.

( EXHIBITS # 13, #14 ) So the now alleged former Alto Properties Inc. Property Manager Stella Reddy even includes a copy of the Applicants Notice of Appeal and Certificate Respecting Evidence in her June 14, 2018 HRTO complaint against them. Verifying she had to know the existence of the Applicants appeal and what was in it for Divisional Court.

This confirms that the now alleged former Alto Properties Inc. Property Manager Stella Reddy had to know the Applicants had appealed the illegal eviction order created by Social Justice Tribunals Ontario Member Kevin Lundy in Divisional Court.

( EXHIBIT # 25 ) The now alleged former Alto Properties Inc. Property Manager Stella Reddy also confirms this in her own email to the HRTO back on December 28, 2017.

“ As per their right, they filed an appeal with Divisional Court that we are waiting on. ” “ including the lawyer the company hired for the Appeal with Divisional Court

( EXHIBIT # 26 ) She also again confirms it in another email to the HRTO back on June 06, 2018.

“ these tenants filed a appeal with Divisional Court for the eviction ”

“ which is still before the court should be heard sometime in Oct 2018. ”

So 8 days after sending the HRTO her email on June 06, 2018. The now alleged former Alto Properties Inc. Property Manager Stella Reddy files her own online HRTO complaint against the Applicants on June 14, 2018.

This also means that the now alleged former Alto Properties Inc. Property Manager Stella Reddy filed her own HRTO complaint against the Applicants, 10 days after they initially filed their HRTO complaints against her on June 04, 2018.

It appears that the now alleged former Alto Properties Inc. Property Manager Stella Reddy filed her own HRTO complaint against the Applicants as a way to retaliate against them for filing against her.

Now reviewing the now alleged former Alto Properties Inc. Property Manager Stella Reddy complaint put in on June 14, 2018.

( EXHIBIT # 27 ) The HRTO can see that under PART 14. Other Proceeding – In Progress, she checks off the box [ YES ] – Are the facts of this Complaint part of another proceeding that is still in progress?

She also checks off the boxes [ A CLAIM BEFORE ANOTHER BOARD, TRIBUAL OR AGENCY ] and [ OTHER ]

She writes in the empty box beside [ OTHER ] “ Divisional Court Appeal for LTB Order issued Oct 3, 2017 of an eviction. Waiting on court date for appeal still, was informed may be in Sept. or Oct. by lawyer retained for the case. ”

The now alleged former Alto Properties Inc. Property Manager Stella Reddy mentions the Divisional Court proceedings, but she conveniently forgets to mention that these same documents that part of 2 other HRTO complaint that was filed against her 10 days earlier by the Applicants.

( EXHIBIT # 27 ) Under Part 15. [ A ] Other Proceeding – Completed ( Where the facts of this Complaint part of some other proceeding that is now completed? ) The now alleged former Alto Properties Inc. Property Manager Stella Reddy checks off the box

( EXHIBIT # 28 ) Under Part 15. [ B ] Other Proceeding – Completed ( Describe the other proceeding: ) The now alleged former Alto Properties Inc. Property Manager Stella Reddy checks off the box – A CLAIM BEFORE ANOTHER BOARD, TRIBUAL OR AGENCY and stated in the empty box beside it “ Landlord Tenant Board, Sept 26, 2017. Order of Eviction issued Oct. 3, 2017 ”

( EXHIBIT # 28 ) Under Part 15. [ C ] Other Proceeding – Completed ( Explain why you believe the other proceeding did not appropriately deal with the substance of this Complaint. )

The now alleged former Alto Properties Inc. Property Manager Stella Reddy stated “ Even though this alleged conversation was mentioned at the LTB hearing, we were there for the refusal of access as they had given us a request for repairs and when we tried to enter to assess what needed I was aggressively refused and had more harassment thrown at me as well as demands that I should have been there earlier instead of making him wait all day. This proceeding started even more harassment as after that they tried to rally other tenants in getting me fired. ”

( EXHIBIT # 27 ) Under Part 14. [ C ] Other Proceeding – Other Proceeding – In Progress ( Are you asking the Tribunal to defer ( postpone ) your Complaint until the other proceeding is completed? ) she checks off the box [ NO ]

So when the now alleged former Alto Properties Inc. Property Manager Stella Reddy checked off she did not wish for her HRTO complaint to be deferred ( postponed ) against the Applicants.

She was well aware that;

  1. There was another proceeding(s) in progress. ( 2 HRTO complaints and a Division Court )
  2. There was another proceeding completed. ( LTB Hearing )

3.       The facts of her complaint were part of another proceeding(s) that is still in progress.

  • The facts of her complaint were part of another proceeding that was completed.

5.       She included documentation that had been handed into the LTB and Divisional Court by the Applicants.

  • She included documentation that had been handed into the HRTO by the Applicants against her.

7.       That 16 pieces or 73% of her own documentation had already been filed by the Applicants at the LTB hearing and/or with the Divisional Court.

  • And that she was NOT “ ASKING THE TRIBUAL TO DEFER ”

The HRTO has to conclude without any doubts that back in June 14, 2018, the now alleged former Alto Properties Inc. Property Manager Stella Reddy thought it was great idea to include the LTB hearing and Divisional Court documents, while she was pushing to have her own HRTO complaint heard against the Applicants and not wanting it to be deferred or postponed.

And therefore what is good for the now alleged former Alto Properties Inc. Property Manager Stella Reddy in her own mind, must be good for everyone, despite who is on the receiving end of it.

Fair is fair and since it appears that the now alleged former Alto Properties Inc. Property Manager Stella Reddy now does not like the changes in the situation. She now wants to try and manipulate the HRTO into believing that she is a victim of her own actions by requesting a deferral and/or dismissal of the HRTO complaints against her.

3

OHH THE LIES

( EXHIBIT # 29 ) As we were just talking about fairness. Let’s take a moment to reflect back to when the now alleged former Alto Properties Inc. Property Manager Stella Reddy was preaching about fairness in her email response to HRTO in her “ August 15.docx ” on August 20, 2018

( EXHIBIT # 30 page # 9 ) The now alleged former Alto Properties Inc. Property Manager Stella Reddy adamantly stated “ So when they asked for a visitors parking pass, I couldn’t give them one or I would have to give it to the rest waiting in order to fair to all tenants. We cannot do for one that we couldn’t do for them all. ”

So as the HRTO can see from her response, the now alleged former Alto Properties Inc. Property Manager Stella Reddy wanted the HRTO to believe that the rules should apply to everyone involved so all can benefit from them, not just the Applicants.

This is why the Applicants were not allowed to park their only vehicle in visitor parking because no other tenants were allowed to based on the rules.

It would be safe to assume that if the roles were to be reversed, and another tenant(s) wished to park their vehicle in visitor parking. They too would not be able to park there as the Applicants were not allowed to by the rules.

A fair translation would be… What is good for one, must be good for all.

But, she got caught lying to the HRTO ( via Applicants video ) about still giving out a Visitor Parking pass to the new all- white unit #306 for their 2nd vehicle, while refusing to give the Applicants that same parking privilege for their only car because of the rules at the very same time.

( EXHIBIT # 31 ) The now alleged former Alto Properties Inc. Property Manager Stella Reddy sends the Applicants a letter stating “ Due to the limited parking spaces available in Visitor Parking area we can’t allow tenant to temporally park there as we do not have enough spaces for all whom are waiting. I am sorry but you will have to find parking space off site as some others have had to do. ”

VIDEO DETAILS FROM PHONE

Attached Video File Name:

( EXHIBIT # 32 ) Unit #306 – The First Two Vehicles in Visitor Parking March 14, 2018.mp4

Both Cars –  First Two Parked Upfront

Assigned Alto Properties Parking Space “ 029 ”

Given a “ Visitor ” Parking Pass

The now alleged former Alto Properties Inc. Property Manager Stella Reddy also got caught lying to the HRTO ( via Applicants video ) about how the Applicants refused to return the required form to obtain a parking spot.

VIDEO DETAILS FROM PHONE

Attached Video File Name:

( EXHIBIT # 33 ) Parking Pass Office  –  March 16, 2018.mp4

( EXHIBIT # 34 ) Applicants Parking Request Form

( EXHIBIT # 35 ) The now alleged former Alto Properties Inc. Property Manager Stella Reddy also got caught lying to the HRTO ( via Applicants video ) about how the Applicants “ are still the only tenants who had a BBQ on their balcony ” in the entire building, despite 4 other tenants having one.

( EXHIBIT # 36 ) Let us remember that 1 out of the 4 other tenants who had BBQ’s is the now alleged former Alto Properties Inc. Property Manager Stella Reddy very own sister who lives is in unit #407, who interesting enough moved in after the BBQ ban was put in place back in July 28, 2016.

“ BBQ’s are also not allowed under City of Toronto Fire Code regulations, as they require BBQ’s to be at least 9 feet away from doors and windows. ( I had to research this act a few years ago when management I worked for at the time wanted to put in a BBQ area for the tenants. ) As we are here to ensure safety of all tenants. It is our job to enforce these rules, so your cooperation would be greatly appreciated. I am hoping by August 5th to see all these items gone or I will have no alternative than to proceed to the Landlord and Tenant Board for enforcement. ”

VIDEO DETAILS FROM PHONE

Attached Video File Name:

( EXHIBIT # 37 ) Unit# 502 BBQ.mp4

Picture of Unit #502 BBQ – August 24, 2018

VIDEO DETAILS FROM PHONE

Attached Video File Name:

( EXHIBIT # 38 ) Unit# 506 BBQ.mp4

Picture of Unit #506 BBQ – August 24, 2018

VIDEO DETAILS FROM PHONE

Attached Video File Name:

( EXHIBIT # 39 ) Unit# 407 & 507 BBQ.mp4

Picture of Unit #407 BBQ – August 24, 2018

( #407 is Stella Reddy sister)

Picture of Unit #507 BBQ – August 24, 2018

( EXHIBIT # 36 ) Not only has the now alleged former Alto Properties Inc. Property Manager Stella Reddy preached about her desire to be fair to everyone. The now alleged former Alto Properties Inc. Property Manager Stella Reddy has even gone on the record numerous times making the claim of being a ruled based person.


“ As we are here to ensure the safety if all tenants it is our job to enforce these rules ”

  • “ I am a rule driven person”

·         “ I follow the rules and regulations ”

Applicants on August 24, 2018 in an attached file called – August 25.docx she stated,

labelled from her August 15.docx.

·         “ It was my job to follow direction of property owners and follow all rules and regulations ”

  • “ It is also our job to enforce the rules ”

·        
“ I am rule driven ”

  • “ I am professional in my dealings with tenants and most times I actually quote the regulations I copy and paste directly from the written rules, as I prefer the rules and regulations ”

·        
“ I am a ruled based person as I believe the rules and regulations of the industry ”

August 21, 2018 to the Applicants.

“ As I continually quoted the rules on my letters and notices by copying and pasting them from the website…, I let the rules and regulations of various agencies we have to answer too speak for me ”

So it is pretty obvious that this way of so – called fairness and “ rule – based ” thinking is not something that she practices for herself in her everyday life. It appears she says these lies in an attempt to convince whoever is listen that she is not a liar and a racist although her own paper and actions seem to say differently.

It is ironic that the now alleged former Alto Properties Inc. Property Manager Stella Reddy has the nerve to send emails and letters to the Applicants where she lays into them about lying and how they have broken the rules so many times and now they must deal with the consequences of their own actions.

( EXHIBIT # 48 ) On the now alleged former Alto Properties Inc. Property Manager Stella Reddy emails Letter 303.docx to the Applicants.

·         “ Each and every time you go against the rules of the Residential Tenancies Act, the Landlord and Tenant Board, including even the property rules, it reflects badly on you and will be used against you. By defying all these rules all it does is tell people that you believe the rules do not apply to you and that you feel you can do what you want in the property. ”

  • “ You have broken so many rules it’s hard to keep track. ”

·           “ you have no respect for the rules, other tenants, the staff, or them? ”

  • “ and be able to abide by the rules like everyone else. ”

·         “ reinforcing those facts: that you have no respect for the rules and regulations of apartment living, the property owners nor the staff, including other tenants, as you refuse to follow the rules then, and continue to do so now, without regard for anyone else, even your own family “

The now alleged former Alto Properties Inc. Property Manager Stella Reddy has had no problem or reservations about lecturing and scolding the Applicants about the consequences of allegedly lying and not following the rules.

She even goes on to state that the relationship between the Applicants and the owners is so “ broken ” that even if the Divisional Court was to rule in their favor. There is no way they could stay in the building because “ It is just not done. ”

It seems like a bit of hypocrisy of the behalf of the now alleged former Alto Properties Inc. Property Manager Stella Reddy to be lecturing and scolding the Applicants about lying when she, herself has been caught without debate so many times lying to the HRTO in her attempts to portray the Applicants in an unfavorable light.

( EXHIBIT #50 ) – Let us remember the now alleged former Alto Properties Inc. Property Manager Stella Reddy deliberately lie under oath, committed perjury at the LTB hearing where she stated her nephew is

“ even darker than she is. ” while pointing at the Applicant.

Comparing pictures of the Applicants and Stella Reddy nieces and nephews, there is an obvious huge direct difference in everyone’s complexions.

It is pretty clear and pretty obvious that the now alleged former Alto Properties Inc. Property Manager Stella Reddy has not only lied to the HTRO, but has also lied to the LTB about the complexion of her own nephew in hopes of trying sway and influence the LTB in her favor.

It is also pretty obvious that the now alleged former Alto Properties Inc. Property Manager Stella Reddy never considered the idea that the Applicants would be able to find anything on Social Media of her nieces and nephews, eventually exposing her lie.

4

DEFER AND/OR DISMISS

The now alleged former Alto Properties Inc. Property Manager Stella Reddy has deliberately made absolutely no arguments, quoted or presented any legal grounds in her written response as to why the complaints against her should be deferred and/or dismissed at her own request.

It is the Applicants position that Alto Properties Inc. Property Manager Stella Reddy has chosen to forfeit her right to have any place at the table to argue any issues relating to her own request for a deferral and/or dismissal, as she has deliberately not presented any documents or argument to collaborate and justify her request for a deferral and/or dismissal that she has requested.

It is the Applicants position that Alto Properties Inc. Property Manager Stella Reddy has taken it upon herself to not present the required documents to collaborate or justify her request for deferral and/or dismissal.

The now alleged former Alto Properties Inc. Property Manager Stella Reddy willfully and without any threats of reprisal, violence, repercussions or intimidation decided that she was not going to address the issue of deferral and/or dismissal that was requested by her in her response.

It appears that the now alleged former Alto Properties Inc. Property Manager Stella Reddy thinks that it is the HRTO responsibility and obligation to make her positions fully known, or to create an argument on her behalf and to present documents that help justify her own request for a deferral and/or dismissal.

It is Applicants position that this is not the case, and that the now alleged former Alto Properties Inc. Property Manager Stella Reddy should not have placed these inappropriate expectations upon HRTO, as it is solely HER responsibility to present, validate and defend her own request for deferral and/or dismissal.

( EXHIBIT # 51 ) The Applicants would like to now clarify an error made by Alto Properties Inc. owner Luigi Liscio and Alto Properties Inc. owner Anthony Liscio in their PART II – FACTS .8 of their Response.

“ The member determined that any racially insensitive remarks that may have been made by an agent of the landlord did not dictate her action, particularly in view of the otherwise valid Notice of Entry. ”

( EXHIBIT # 52 ) The Applicants would like to state that that Social Justice Tribunals Ontario Member Kevin Lundy clearly addressed that the now alleged former Alto Properties Inc. Property Manager Stella Reddy as “ MADE ”, not “ MAY ”…

It appears that by Alto Properties Inc. owner Luigi Liscio and Alto Properties Inc. owner Anthony Liscio want to down play the now alleged former Alto Properties Inc. Property Manager Stella Reddy racially charged language and prejudice slurs and actions made at the LTB Hearing.

The Applicants would like to now address that fact that Alto Properties Inc. owner Luigi Liscio and Alto Properties Inc. owner Anthony Liscio handed in 9 pieces of authorities to support their own request for deferral and/or dismissal.

( EXHIBIT # 53 ) Of this list of 9 authorities, Alto Properties Inc. owner Luigi Liscio and Alto Properties Inc. owner Anthony Liscio only refer to 5 of the list in their PART III – ISSUES AND THE LAW. #3, 4, 5, 7, 8.

( EXHIBIT # 54 )

Cordero and Hydro One Networks Inc. 2015 HRTO 1312 Carlos and 1174364 Ontario Ltd. and Ferreira   2008 HRTO 403

Ornelas and Casamici Restaurant and Sciulli   2010 HRTO 1078

British Columbia ( WCB ) and Figiola   2011 3 SCR 422

Seberras and Work Safety and Insurance Board   2012 HRTO 115

page # 07 ( 26. )

page # 10 ( 30. )

page # 11 ( 35. 37. 38. )

page # 13 ( 44. )

page # 12 ( 39. 41. 42 )

page # 13 ( 43. 44. )

page # 14 + 15 ( 48. )

page # 07 ( 22.)

page # 08 ( 24. )

page # 15 ( 51.)

page # 15 ( 49. )

The Applicants notes that Alto Properties Inc. owner Luigi Liscio and Alto Properties Inc. owner Anthony Liscio counsel David Strashin have not provided the HRTO or the Applicants with any type of physical copy or digital copy of the authorities they referenced and rely upon in their request for a deferral and/or dismissal.

( EXHIBIT # 55 ) It is the position of the Applicants that like the Divisional Court, Alto Properties Inc. owner Luigi Liscio and Alto Properties Inc. owner Anthony Liscio have a mandatorily obligation to supply the HRTO and the Applicants with either with a physical copy or digital copy of any authorities they reference and rely upon in their request for a deferral and/or dismissal.

( EXHIBIT # 54 ) Alto Properties Inc. owner Luigi Liscio and Alto Properties Inc. owner Anthony Liscio also referenced and rely upon – Noble and York University 2010 HRTO 878 – page # 14 ( 47. ) in their request for a deferral and/or dismissal.

This reference is not part their list of 9 authorities, nor again was the HRTO or the Applicants given any type of physical copy or digital copy of this authority that they referenced and rely upon in their response request for a deferral and/or dismissal.

Again it is the position of the Applicants that like the Divisional Court, Alto Properties Inc. owner Luigi Liscio and Alto Properties Inc. owner Anthony Liscio have a mandatorily obligation to supply the HRTO and the Applicants either with a physical copy or digital copy of this authority they reference and rely upon in their request for a deferral and/or dismissal.

( EXHIBIT # 56 ) The Applicants sent Alto Properties Inc. owner Luigi Liscio and Alto Properties Inc. owner Anthony Liscio counsel David Strashin an email on November 27, 2017 asking him he could please supply them with a .pdf copy or a link for #7 and #9 as they are part of their list of authorities.

The Applicants request was again intentionally ignored by Alto Properties Inc. owner Luigi Liscio and Alto Properties Inc. owner Anthony Liscio and their counsel David Strashin as they have previously done in bad faith in the past when the Applicants have made other request.

Alto Properties Inc. owner Luigi Liscio and Alto Properties Inc. owner Anthony Liscio and their counsel David Strashin deliberately in bad faith ignored the Applicants request in hopes to limit and impede their past LTB hearing compliant and now with their complaints with the HRTO against his clients.

Alto Properties Inc. owner Luigi Liscio and Alto Properties Inc. owner Anthony Liscio and their counsel David Strashin have continued to act in bad faith as they have now deliberately not provide a physical copy or digital copy of their authorities that they reference and rely upon in their response requesting for a deferral and/or dismissal.

It appears that because the Applicants are representing themselves in these HRTO complaints due to finical restrictions. Alto Properties Inc. owner Luigi Liscio and Alto Properties Inc. owner Anthony Liscio and their counsel David Strashin think this again is a great time to trying to capitalize upon it and use it to their advantage.

It appears that Alto Properties Inc. owner Luigi Liscio and Alto Properties Inc. owner Anthony Liscio and their counsel David Strashin have relied on the hope that the Respondents will not have access or be able to figure out where to get any authority’s , therefore not getting access to theirs and therefore they won’t be able to argue it adequately.

It appears that Alto Properties Inc. owner Luigi Liscio and Alto Properties Inc. owner Anthony Liscio and their counsel David Strashin have relied on the hope that if the Respondents do have access to authorities. They are hoping to make the Applicants find more finical difficulties by having to print out the long LIST OF AUTHORIES they have reference and relied upon in their response requesting for a deferral and/or dismissal.

Like Alto Properties Inc. owner Luigi Liscio and Alto Properties Inc. owner Anthony Liscio, their counsel David Strashin has again acted in bad faith when presenting his clients response by deliberately not provide a physical copy or digital copy of their authorities that they reference and rely upon in their response requesting for a deferral and/or dismissal.

It also needs to be noted that Alto Properties Inc. owner Luigi Liscio and Alto Properties Inc. owner Anthony did create a 15 page response to the HRTO citing so many different issues like,

After quoting so many parts of the Act, over and over. Alto Properties Inc. owner Luigi Liscio and Alto Properties Inc. owner Anthony have still only present very limited explanations about their authorities and are so vaguely explained or in some cases lack any type of explanation at all.

Due to this improper conduct by Alto Properties Inc. owner Luigi Liscio and Alto Properties Inc. owner Anthony Liscio and their counsel David Strashin.

It is the Applicants position that Alto Properties Inc. owner Luigi Liscio and Alto Properties Inc. owner Anthony Liscio have chosen to forfeit their right to have any place at the table to argue any issues relating to their own request for a deferral and/or dismissal, as they have deliberately not provide a physical copy or digital copy of their authorities, present explanations about their authorities that are so vaguely explained or in some cases lack any type of explanation at all to justify their request for a deferral and/or dismissal that they had requested.

It is the Applicants position that Alto Properties Inc. owner Luigi Liscio and Alto Properties Inc. owner Anthony Liscio have taken it upon themselves to deliberately not present the required documents to collaborate or justify their request for deferral and/or dismissal.

Alto Properties Inc. owner Luigi Liscio and Alto Properties Inc. owner Anthony Liscio willfully and without any threats of reprisal, violence, repercussions or intimidation decided that they were not going to address some issue raised in their request for deferral and/or dismissal that was requested by them in their response.

It appears that Alto Properties Inc. owner Luigi Liscio and Alto Properties Inc. owner Anthony Liscio think that it is the HRTO responsibility and obligation to make their positions fully known, or to create an argument on their behalf and to present documents that help justify their own request for a deferral and/or dismissal.

It is Applicants position that this is not the case, and that Alto Properties Inc. owner Luigi Liscio and Alto Properties Inc. owner Anthony Liscio should not have placed these inappropriate expectations upon HRTO, as it is solely THEIR responsibility to present, validate and defend their own request for deferral and/or dismissal.

5

OTHER ONGOING LEGAL PROCEEDINGS

The now alleged former Alto Properties Inc. Property Manager Stella Reddy has deliberately made absolutely no arguments, quoted or presented any legal grounds in her written response to this issue.

It is the Applicants position that Alto Properties Inc. Property Manager Stella Reddy has chosen to forfeit her right to have any place at the table to argue any issues relating to other ongoing legal proceedings, as she has deliberately not presented any documents or argument to collaborate and justify her request for a deferral and/or dismissal that she has requested.

It is the Applicants position that Alto Properties Inc. Property Manager Stella Reddy has taken it upon herself to not present the required documents to collaborate or justify her request for deferral and/or dismissal.

The now alleged former Alto Properties Inc. Property Manager Stella Reddy willfully and without any threats of reprisal, violence, repercussions or intimidation decided that she was not going to address the issue of deferral and/or dismissal that was requested by her in her response.

It appears that the now alleged former Alto Properties Inc. Property Manager Stella Reddy thinks that it is the HRTO responsibility and obligation to make her positions fully known, or to create an argument on her behalf and to present documents that help justify her own request for a deferral and/or dismissal.

It is Applicants position that this is not the case, and that the now alleged former Alto Properties Inc. Property Manager Stella Reddy should not have placed these inappropriate expectations upon HRTO, as it is solely HER responsibility to present, validate and defend her own request for deferral and/or dismissal.

It is the Applicants position that Alto Properties Inc. owner Luigi Liscio and Alto Properties Inc. owner Anthony Liscio have chosen to forfeit their right to have any place at the table to argue any issues relating to other ongoing legal proceedings for a deferral and/or dismissal, as they have deliberately not provide a physical copy or digital copy of their authorities, present explanations about their authorities that are so vaguely explained or in some cases lack any type of explanation at all to justify their request for a deferral and/or dismissal that they had requested.

It is the Applicants position that Alto Properties Inc. owner Luigi Liscio and Alto Properties Inc. owner Anthony Liscio have taken it upon themselves to deliberately not present the required documents to collaborate or justify their request for deferral and/or dismissal.

Alto Properties Inc. owner Luigi Liscio and Alto Properties Inc. owner Anthony Liscio willfully and without any threats of reprisal, violence, repercussions or intimidation decided that they were not going to address some issue raised in their request for deferral and/or dismissal that was requested by them in their response.

It appears that Alto Properties Inc. owner Luigi Liscio and Alto Properties Inc. owner Anthony Liscio think that it is the HRTO responsibility and obligation to make their positions fully known, or to create an argument on their behalf and to present documents that help justify their own request for a deferral and/or dismissal.

It is Applicants position that this is not the case, and that Alto Properties Inc. owner Luigi Liscio and Alto Properties Inc. owner Anthony Liscio should not have placed these inappropriate expectations upon HRTO, as it is solely THEIR responsibility to present, validate and defend their own request for deferral and/or dismissal.

It is the position of the Applicants that due to the inadequate responses by the 3 Respondents, it is clear that they are relying solely upon the fact that there are two legal proceedings ongoing to justify having the complaints by the Applicants to be deferred and/or dismissed. It has been acknowledged in numerous authorities that a deferral is not simply invoked simple because there are other ongoing legal proceedings.

“ [9] Deferral is not automatically indicated simply because the parties are involved in other legal proceedings.”

“ [12] Deferral is not automatically invoked simply because the parties are involved in other legal proceedings.”

“ [18] However, deferral is not automatically invoked simply because the parties are involved in other legal proceedings. ”

“ [4] However, deferral is not automatically invoked simply because the parties are involved in other legal proceedings. ”

“ [11] It is not automatically invoked simply because the parties are involved in other legal processes, but is a discretionary measure that the Tribunal exercises on the basis of the circumstances of each case. ”

“ [42] However, deferral is not automatically invoked simply because the parties are involved in other legal proceedings. ”

“ [13] However, deferral is not automatically invoked simply because the parties are involved in other legal proceedings. ”

“ [6] It is not automatically invoked simply because the parties are involved in other legal processes ”

“ [7] However, deferral is not automatically invoked simply because the parties are involved in other legal proceedings. ”

“ [8] However, deferral is not automatically invoked simply because the parties are involved in other legal proceedings. ”

“ [9] However, the respondents have requested deferral of the Complaint to another proceeding ”

6

“ BEFORE ME ”

The now alleged former Alto Properties Inc. Property Manager Stella Reddy has deliberately made absolutely no arguments, quoted or presented any legal grounds in her written response to this issue.

It is the Applicants position that Alto Properties Inc. Property Manager Stella Reddy has chosen to forfeit her right to have any place at the table to argue any issues relating to her own request for a deferral and/or dismissal, as she has deliberately not presented any documents or argument to collaborate and justify her request for a deferral and/or dismissal that she has requested.

It is the Applicants position that Alto Properties Inc. Property Manager Stella Reddy has taken it upon herself to not present the required documents to collaborate or justify her request for deferral and/or dismissal.

The now alleged former Alto Properties Inc. Property Manager Stella Reddy willfully and without any threats of reprisal, violence, repercussions or intimidation decided that she was not going to address the issue of deferral and/or dismissal that was requested by her in her response.

It appears that the now alleged former Alto Properties Inc. Property Manager Stella Reddy thinks that it is the HRTO responsibility and obligation to make her positions fully known, to create an argument on her behalf and to present documents that help justify her own request for a deferral and/or dismissal.

It is Applicants position that this is not the case, and that the now alleged former Alto Properties Inc. Property Manager Stella Reddy should not have placed these inappropriate expectations upon HRTO, as it is solely HER responsibility to present, validate and defend her own request for deferral and/or dismissal.

It is the Applicants position that Alto Properties Inc. owner Luigi Liscio and Alto Properties Inc. owner Anthony Liscio have chosen to forfeit their right to have any place at the table to argue this issues relating to their own request for a deferral and/or dismissal, as they have deliberately not provide a physical copy or digital copy of their authorities, present explanations about their authorities that are so vaguely explained or in some cases lack any type of explanation at all to justify their request for a deferral and/or dismissal that they had requested.

It is the Applicants position that Alto Properties Inc. owner Luigi Liscio and Alto Properties Inc. owner Anthony Liscio have taken it upon themselves to deliberately not present the required documents to collaborate or justify their request for deferral and/or dismissal.

Alto Properties Inc. owner Luigi Liscio and Alto Properties Inc. owner Anthony Liscio willfully and without any threats of reprisal, violence, repercussions or intimidation decided that they were not going to address some issue raised in their request for deferral and/or dismissal that was requested by them in their response.

It appears that Alto Properties Inc. owner Luigi Liscio and Alto Properties Inc. owner Anthony Liscio think that it is the HRTO responsibility and obligation to make their positions fully known, or to create an argument on their behalf and to present documents that help justify their own request for a deferral and/or dismissal.

It is Applicants position that this is not the case, and that Alto Properties Inc. owner Luigi Liscio and Alto Properties Inc. owner Anthony Liscio should not have placed these inappropriate expectations upon HRTO, as it is solely THEIR responsibility to present, validate and defend their own request for deferral and/or dismissal.

It is the position of the Applicants that due to the inadequate responses by the 3 Respondents, it is clear that they are relying solely of the fact of their opinions to justify having the complaints by the Applicants to be deferred and/or dismissed. It has been acknowledged in numerous authorities that the HRTO can only consider the documents presented to them by the parties involved in these complaints before them. And in turn means that the HRTO can only make a finding based on this said documents.

“ [5] Based on the documents before me ”

“ 12] Based on the information provided by the parties, ”

“ [15] while the respondent had filed a WSIB appeal, there is no information before me about the status of the appeal before WSIB or the timeframe within which it will be determined. ”

“ [10] Based on the information provided by the parties ”

“ [17] The document before me ”

“ [8] there is no information before the Tribunal to indicate that proceeding

with the human rights Complaints would create a real risk of inconsistent decisions on the factual or legal issues raised in the Complaints. In the absence of such risk,

deferring the Complaints would be inconsistent with the Tribunal’s mandate of ensuring the fair, just and expeditious resolution of Complaints.”

“ [7] On the basis of the limited documents before me ”

“ [22] Moreover, on the information before me ”

“ [14] In reviewing the documents provided by the respondent on the ESA appeal ”

“ [19] there is nothing in the document submitted ”

“ [7] There is no information before the Tribunal ”

It is clear that the 3 Respondents requested deferral and/or dismissal and not the HRTO.

And still the now alleged former Alto Properties Inc. employee Stella Reddy does not address the issue of deferral and/or dismissal. Instead she goes on a 16 page rant to the HRTO where she was obviously more concerned about examining the irrelevant issues of;

1.                                         How bad the Applicants are.

  • Her and her husband’s previous employment and living history.

3.                                         All of her and her husband’s past and present finical difficulties.

  • How the Applicants and 3 other units start a tenant association.

5.                                         Her experience in a house fire.

  • Her past and current metal health issues.

7.                                             Her past and current history of physical injuries.

  • The current state of her mother’s health problems.

9.                                         Explaining what Psychosis is.

  1. How the Applicants will most certainly lose in Divisional Court.

11.                                     Her transgender son’s personal battles and history.

  1. Her other son and his history with Attention Deficit Disorder when he was 4 years old.

13.                                     Her other son and his fiancé who is from Chile.

  1. How she was a single mother.

No matter how times the Applicants read the now alleged former Alto Properties Inc. Property Manager Stella Reddy 16 page response given to the HRTO. They can make absolutely no connection between above irrelevant issues and the HRTO complaints against her and her request for a deferral and/or dismissal.

It is clear that the now alleged former Alto Properties Inc. employee Stella Reddy is trying to gain some form of sympathy again from the HRTO in hopes of getting a favorable outcome for her request.

It is mind boggling to think, that she thinks these irrelevant issues can possible have any relevance or role in her defence to help justify her own request for a deferral and/or dismissal.

It appears the now alleged former Alto Properties Inc. employee Stella Reddy is doing as she has previous done with others, and that is trying to play like she is the victim and that she has been dealt such a rough hand in life.

It is the Applicants position that Alto Properties Inc. owner Luigi Liscio and Alto Properties Inc. owner Anthony Liscio have chosen to forfeit their right to have any place at the table to argue any issues relating to their own request for a deferral and/or dismissal, as they have deliberately not provide a physical copy or digital copy of their authorities, present explanations about their authorities that are so vaguely explained or in some cases lack any type of explanation at all to justify their request for a deferral and/or dismissal that they had requested.

It is the Applicants position that the 3 Respondents have taken it upon themselves to not present the required documents to collaborate or justify their request for deferral and/or dismissal.

The 3 Respondents willfully and without any threats of reprisal, violence, repercussions or intimidation decided that they were not going to address the issue in their request deferral and/or dismissal by them in their response.

It appears that the 3 Respondents think that it is the HRTO responsibility and obligation to make their positions fully known, to create an argument on their behalf and to present materials that help justify their own request for a deferral and/or dismissal.

It is Applicants position that this is not the case, and that the 3 Respondents should not have placed these inappropriate expectations upon HRTO, as it is solely THEIR responsibility to present, validate and defend their own request for deferral and/or dismissal.

7

OVERLAPPING DOCUMENTS, NOT EVIDENCE

Despite the 3 Respondents deliberately not presenting any supporting documents in regards to their request for a deferral and/or dismissal.

The Applicants stand by the position that the HRTO can hear the Applicants complaints against the 3 Respondents despite the issues that there are two ongoing proceedings that appear to have some minimal overlapping of documents and not evidence.

There can be no argument after reviewing this section; the HRTO will see that Social Justice Tribunals Ontario Member Kevin Lundy denied the Applicants their right to present a full defence against the 3 Respondents.

There can be no argument after reviewing this section and the HRTO will see that Social Justice Tribunals Ontario Member Kevin Lundy deceived them into handing in their documents for the hearing, than he subsequently shot down their attempts to explain its relevance and role during that same hearing.

The Applicants take the position that documents handed in at the LTB hearing is considered just that, documents. It cannot be considered as evidence.

Evidence is defined as;

  • A thing or set of things helpful in forming a conclusion or judgment.

Reading the above definition, it is clear that evidence has to HELP prove or disprove a situation and/or be used to HELP

form a conclusion or judgement.

It is the Applicants position that the provided documents at the LTB hearing by the Applicants do not fit this above definition of evidence.

As the Applicants were not given an impartial opportunity to explain the relevance and role of the documents they were deceived into handing in. There is no way it could have helped the Social Justice Tribunals Ontario Member Kevin Lundy in coming to a final conclusion.

In fact reviewing the Social Justice Tribunals Ontario Member Kevin Lundy illegal eviction order of October 03, 3017. It is pretty clear that he makes no reference to the Applicants documents when making his conclusion.

This is because at that time of the LTB hearing, there were only two people in the entire world of 7.7 billion people that had any idea what the document could have meant and it was only the Applicant and her husband.

There was no way and it would have been impossible anyone to understand relevance of the documents. It would not have been until June 06, 2018 when the Applicants emailed their HRTO complaints to the 3 Respondents, along with the 107 page Statement of Facts. That they themselves could have even begin to grasp what the documents served in the LTB hearing back on September 26, 2017 could have meant or how the Applicants planned to use it.

So when the document ( not evidence ) was requested/implied to be submitted deceitfully into file at the request of the Social Justice Tribunals Ontario Member Kevin Lundy at the LTB hearing.

The Social Justice Tribunals Ontario Member Kevin Lundy never allowed the Applicants a fair and objective opportunity explain the relevance or connection of these documents as a defence.

The facts are that the entire Divisional Court hearing is not based on the documents presented to the LTB hearing, but it is solely based on the conduct of the Social Justice Tribunals Ontario Member Kevin Lundy.

The appeal is strictly about the many bias and serious errors of law made by the Social Justice Tribunals Ontario Member Kevin Lundy against the Applicant.

The documents handed in to Divisional Court will only be discussed as to its general an overall relevance to the appeal against the Social Justice Tribunals Ontario Member Kevin Lundy and not as individual value.

Meaning the document itself will not be explained in detail as to what each page meant in regards to the 3 Respondents and their harassing, discriminating and acting in a reprisal manner, but how it would have helped the Applicant in her defence at the LTB hearing.

The only questions the Divisional Court will have in regards to the document will be,

  1. Why did Social Justice Tribunals Ontario Member Kevin Lundy not allow the Applicants the opportunity to explain the significance of the documents?

– and –

  • A general/simple explanation as to how it could it have helped the Applicant in her defence against the racial motivated N5 attacks by the 3 Respondents?

( EXHIBIT # 83 ) Reviewing the LTB hearing transcripts and/or listening to the recording. You can see/hear the Social Justice Tribunals Ontario Member Kevin Lundy encourage the Applicant and her husband not to present “ SAVE ” their evidence as it might affect their own hearing on October 31, 2017.

Also the Social Justice Tribunals Ontario Member Kevin Lundy refused to hear the Applicants defence against the

3 Respondents despite having the power to amend them for October 31, 2017.

( EXHIBIT # 84 ) Social Justice Tribunals Ontario Member Kevin Lundy also encouraged the 3 Respondents “ not ” to adjourn and hear them together on October 31, 2017.

Reviewing all the document provided above and to the LTB, it is clear that a huge amount of the Applicants documents was never discussed for a defence as Social Justice Tribunals Ontario Member Kevin Lundy was trying to rush and push the proceedings along.

Essentially this huge amount of undiscussed documents was just a giant paper weight on the Social Justice Tribunals Ontario Member Kevin Lundy desk. It was a pile if insignificant documents towards the Applicants defence from the racial motivated N5 attacks by the 3 Respondents.

There is no way that Social Justice Tribunals Ontario Member Kevin Lundy could have reviewed the undiscussed document and been able to conclude or use any of it to make any determination as the relevance of it, let alone how the Applicants planned to use of it in a defence.

The undiscussed documents had about as much value and weight in the Social Justice Tribunals Ontario Member Kevin Lundy final order as a bag of rocks on his desk would have been!

It also appears that the Social Justice Tribunals Ontario Member Kevin Lundy found no importance it the racially charged language and prejudice slurs and actions made by the now alleged former Alto Properties Inc. Property Manager Stella Reddy during the hearing in front of him.

( EXHIBIT # 85 ) The Social Justice Tribunals Ontario Member Kevin Lundy allow her to repeatedly say  staggering things and then he consciously wrote it off as her being “ oblivious ” to her own ignorance to justify his illegal eviction order.

It is clear that the Social Justice Tribunals Ontario Member Kevin Lundy did not even want to consider the possibility that maybe the 3 Respondents had and were harassing, discriminating and acting in a reprisal manner

against the Applicants.

Unlike that the Social Justice Tribunals Ontario Member Kevin Lundy, the Applicants take the position that the now alleged former Alto Properties Inc. Property Manager Stella Reddy was not “oblivious ” to her racially charged language, prejudice slurs and racially motivated actions.

The position of the Applicants is that the now alleged former Alto Properties Inc. Property Manager Stella Reddy JUST DID NOT CARE, AND DID IT WITHOUT FEAR!

It appears that all Social Justice Tribunals Ontario Member Kevin Lundy only cared about was nothing more than hearing all the positive things the 3 Respondents had to say to justify their that racial motivated N5 attacks against the Applicant.

( EXHIBIT # 86 ) This is confirmed by the now alleged former Alto Properties Inc. Property Manager Stella Reddy HRTO complaint on June 14, 2018 where she stated “ Even though this alleged conversation was mentioned at the LTB hearing, we were there for the refusal of access as they had given us a request for repairs and when we tried to enter to assess what needed I was aggressively refused and had more harassment thrown at me as well as demands that I should have been there earlier instead of making him wait all day. This proceeding started even more harassment as after that they tried to rally other tenants in getting me fired. ”

( EXHIBIT # 87 ) It was also confirmed again by the now alleged former Alto Properties Inc. Property Manager Stella Reddy in an email to the Applicants on September 08, 2018 where she stated “ You did forget to mention that you were brought to the LTB for refusal of access for repairs, as that is the only reason, but it is there in the order you have online so easy to find. ”

Even the now alleged former Alto Properties Inc. Property Manager Stella Reddy has realized that the Social Justice Tribunals Ontario Member Kevin Lundy was only there to deal with the Refusal Of Entry. Which means that the Social Justice Tribunals Ontario Member Kevin Lundy at no time was considering the Applicants document when he deceitfully convinces them to hand in their October 31, 2017 LTB complaint documents on September 26, 2017.


( EXHIBIT # 88 )

“ [10] The mere fact that the civil claim and the Complaint arise out of the same factual circumstances is not a sufficient basis upon which to conclude that an Complaint is barred under s. 34(11) ”

“ [11] As the applicant quite rightly points out, and unlike the cases relied upon by the respondents, the civil proceeding commenced by the applicant in this case does not allege that the respondents infringed his rights under the Code or seek a remedy in respect of such infringement. Accordingly, I find that the Complaint is not barred pursuant to s. 34(11) of the Code and the Request to Dismiss on this basis is denied. ”

It is also the Applicants position that the now alleged former Alto Properties Inc. Property Manager Stella Reddy has deliberately made absolutely no arguments, quoted or presented any legal grounds in her written response to this issue.

It is the Applicants position that Alto Properties Inc. Property Manager Stella Reddy has chosen to forfeit her right to have any place at the table to argue any issues relating to overlapping, as she has deliberately not presented any documents or argument to collaborate and justify her request for a deferral and/or dismissal that she has requested.

It is the Applicants position that Alto Properties Inc. Property Manager Stella Reddy has taken it upon herself to not present the required documents to collaborate or justify her request for deferral and/or dismissal.

The now alleged former Alto Properties Inc. Property Manager Stella Reddy willfully and without any threats of reprisal, violence, repercussions or intimidation decided that she was not going to address the issue of deferral and/or dismissal that was requested by her in her response.

It appears that the now alleged former Alto Properties Inc. Property Manager Stella Reddy thinks that it is the HRTO responsibility and obligation to make her positions fully known, or to create an argument on her behalf and to present documents that help justify her own request for a deferral and/or dismissal.

It is Applicants position that this is not the case, and that the now alleged former Alto Properties Inc. Property Manager Stella Reddy should not have placed these inappropriate expectations upon HRTO, as it is solely HER responsibility to present, validate and defend her own request for deferral and/or dismissal.

It is the Applicants position that Alto Properties Inc. owner Luigi Liscio and Alto Properties Inc. owner Anthony Liscio have chosen to forfeit their right to have any place at the table to argue any issues relating to overlapping for a deferral and/or dismissal, as they have deliberately not provide a physical copy or digital copy of their authorities, present explanations about their authorities that are so vaguely explained or in some cases lack any type of explanation at all to justify their request for a deferral and/or dismissal that they had requested.

It is the Applicants position that Alto Properties Inc. owner Luigi Liscio and Alto Properties Inc. owner Anthony Liscio have taken it upon themselves to deliberately not present the required documents to collaborate or justify their request for deferral and/or dismissal.

Alto Properties Inc. owner Luigi Liscio and Alto Properties Inc. owner Anthony Liscio willfully and without any threats of reprisal, violence, repercussions or intimidation decided that they were not going to address some issue raised in their request for deferral and/or dismissal that was requested by them in their response.

It appears that Alto Properties Inc. owner Luigi Liscio and Alto Properties Inc. owner Anthony Liscio think that it is the HRTO responsibility and obligation to make their positions fully known, or to create an argument on their behalf and to present documents that help justify their own request for a deferral and/or dismissal.

It is Applicants position that this is not the case, and that Alto Properties Inc. owner Luigi Liscio and Alto Properties Inc. owner Anthony Liscio should not have placed these inappropriate expectations upon HRTO, as it is solely THEIR responsibility to present, validate and defend their own request for deferral and/or dismissal.

It is the position of the Applicants that due to the inadequate responses by the 3 Respondents, it is clear that they are relying solely upon the fact that there are two legal proceedings ongoing to justify having the complaints by the Applicants to be deferred and/or dismissed. It has been acknowledged in numerous authorities that a deferral is not simply invoked simple because the same factual circumstances arise in other ongoing legal proceedings.

8

AVOIDING INCONSISTENT FINDINGS OF FACTS OF LAW

It is also the Applicants position that the now alleged former Alto Properties Inc. Property Manager Stella Reddy has deliberately made absolutely no arguments, quoted or presented any legal grounds in her written response to this issue.

It is the Applicants position that Alto Properties Inc. Property Manager Stella Reddy has chosen to forfeit her right to have any place at the table to argue any issues relating to inconsistent findings, as she has deliberately not presented any documents or argument to collaborate and justify her request for a deferral and/or dismissal that she has requested.

It is the Applicants position that Alto Properties Inc. Property Manager Stella Reddy has taken it upon herself to not present the required documents to collaborate or justify her request for deferral and/or dismissal.

The now alleged former Alto Properties Inc. Property Manager Stella Reddy willfully and without any threats of reprisal, violence, repercussions or intimidation decided that she was not going to address the issue of deferral and/or dismissal that was requested by her in her response.

It appears that the now alleged former Alto Properties Inc. Property Manager Stella Reddy thinks that it is the HRTO responsibility and obligation to make her positions fully known, or to create an argument on her behalf and to present documents that help justify her own request for a deferral and/or dismissal.

It is Applicants position that this is not the case, and that the now alleged former Alto Properties Inc. Property Manager Stella Reddy should not have placed these inappropriate expectations upon HRTO, as it is solely HER responsibility to present, validate and defend her own request for deferral and/or dismissal.

It is the Applicants position that Alto Properties Inc. owner Luigi Liscio and Alto Properties Inc. owner Anthony Liscio have chosen to forfeit their right to have any place at the table to argue any issues relating to inconsistent findings for a deferral and/or dismissal, as they have deliberately not provide a physical copy or digital copy of their authorities, present explanations about their authorities that are so vaguely explained or in some cases lack any type of explanation at all to justify their request for a deferral and/or dismissal that they had requested.

It is the Applicants position that Alto Properties Inc. owner Luigi Liscio and Alto Properties Inc. owner Anthony Liscio have taken it upon themselves to deliberately not present the required documents to collaborate or justify their request for deferral and/or dismissal.

Alto Properties Inc. owner Luigi Liscio and Alto Properties Inc. owner Anthony Liscio willfully and without any threats of reprisal, violence, repercussions or intimidation decided that they were not going to address some issue raised in their request for deferral and/or dismissal that was requested by them in their response.

It appears that Alto Properties Inc. owner Luigi Liscio and Alto Properties Inc. owner Anthony Liscio think that it is the HRTO responsibility and obligation to make their positions fully known, or to create an argument on their behalf and to present documents that help justify their own request for a deferral and/or dismissal.

It is Applicants position that this is not the case, and that Alto Properties Inc. owner Luigi Liscio and Alto Properties Inc. owner Anthony Liscio should not have placed these inappropriate expectations upon HRTO, as it is solely THEIR responsibility to present, validate and defend their own request for deferral and/or dismissal.

It is the position of the Applicants that due to the inadequate responses by the 3 Respondents, it is clear that they are relying solely upon the fact that there are two legal proceedings ongoing to justify having the complaints by the Applicants to be deferred and/or dismissed. It has been acknowledged in numerous authorities that a deferral is not simply invoked simple because the same factual circumstances arise in other ongoing legal proceedings.

Upon reading the Applicants Notice of Appeal and Appellants Factum filed with the Divisional Court. It should be pretty clear and obvious the proceedings in Divisional Court will not be addressing any of the allegations raised in the HRTO complaints filed by the Applicants against the 3 Respondents in regards to their harassment, discriminating and acting in a reprisal manner against them.

( EXHIBIT # 89 ) THE GROUNDS OF APPEAL are as follows:

Social Justice Tribunals Ontario Member Kevin Lundy seriously erred in providing inadequate written reasons in the order issued on under Section 68 – Residential Tenancies Act, 2006 dated October 3, 2017 ( File TEL

  • 83876 – 17 ) and is a serious error of law.

The decision by Social Justice Tribunals Ontario Member Kevin Lundy seriously erred as it is without adequate reasons set out in the order constitutes an error in the fact finding process and is a serious error of law.

Social Justice Tribunals Ontario Member Kevin Lundy verbal actions resulted in him creating a serious error of law at the hearing at 2275 Midland Avenue, Unit # 2, Toronto, Ontario, M1P2E7 on September 26, 2017 ( File TEL – 83876 – 17 ) which resulted in the infringement and violation of Allison Read rights under:

  • Residential Tenancies Act, 2006;
    • Constitution Act – Canadian Charter of Rights and Freedoms;
    • Rights to Natural Justice;
    • Canadian Bill of Rights.

Social Justice Tribunals Ontario Member Kevin Lundy physical actions resulted in him creating a serious error of law at the hearing at 2275 Midland Avenue, Unit # 2, Toronto, Ontario, M1P2E7 on September 26, 2017 ( File TEL – 83876 – 17 ) which resulted in the infringement and violation of Allison Read rights under:

  • Residential Tenancies Act, 2006;
    • Constitution Act – Canadian Charter of Rights and Freedoms;
    • Rights to Natural Justice;
    • Canadian Bill of Rights.

When Social Justice Tribunals Ontario Member Kevin Lundy generated and order under Section 68 – Residential Tenancies Act, 2006 dated October 3, 2017 at 2275 Midland Avenue, Unit # 2, Toronto, Ontario, M1P2E7 resulted in him creating a serious error of law which resulted in the infringement and violation of Allison Read rights under:

  • Residential Tenancies Act, 2006;
    • Constitution Act – Canadian Charter of Rights and Freedoms;
    • Rights to Natural Justice;
    • Canadian Bill Of Rights.
RESIDENTIAL TENANCIES ACT, 2006

Part 1 – Purposes of Act – 1.

Part 3 – Landlord’s responsibility to repair – 20. (1)

Part 3 – Landlord not to interfere with reasonable enjoyment – 22.

Part 3 – Landlord not to harass, etc. – 23. Part 3 – Privacy – 25.

Part 3 – Privacy – 25 . 1

Part 3  –  Entry With Notice  –  27. (1) 4

Part 3  –  Entry With Notice  –  27. (1) 5

Part 3  –  Tenant complaints  –  29. (1) 1

Part 3  –  Tenant complaints  –  29. (1) 3

Part 3 – Tenant complaints – 29. (1) 4 Part 12 – Expeditious procedures – 183

Part 12 – Board may mediate  –  194. (1) (5) Part 12 – Where Board may dismiss – 197. (1) Part 12 – Same (2)

Part 12 – Other powers of Board – 201. (1) (c) Part 12 – Other powers of Board – 201. (1) (f). Part 12 – Other powers of Board – (2)

Part 12  –  Findings of Board  –  202. Part 12 – Conditions in order – 204. (1)

CANADIAN CHARTER OF RIGHTS AND FREEDOMS

Life, liberty and security of person – 7. Proceedings in criminal and penal matters – 11. b) Proceedings in criminal and penal matters – 11. (d) Treatment or punishment – 12.

Interpreter – 14.

Equality before and under law and equal protection and benefit of law 15. (1) Enforcement of guaranteed rights and freedoms – 24. (1)

Exclusion of evidence bringing administration of justice into disrepute – (2) (1) Multicultural heritage – 27.

Rights guaranteed equally to both sexes – 28.

NATURAL JUSTICE

An error in procedure that might have caused prejudice to a party

Natural justice has been described as “fair play in action – the principles and procedures which in any particular situation or set of circumstances are right and just and fair” Its rules have been traditionally divided into two parts: Audi alteram partem – the duty to give persons affected by a decision a reasonable opportunity to present their case.

Natural justice has been described as “fair play in action – the principles and procedures which in any particular situation or set of circumstances are right and just and fair” Its rules have been traditionally divided into two parts: Nemo judex in causa sua debet esse ( No one should be a judge in his own case ) – the duty to reach a decision untainted by bias.

An unreasonable exercise of discretion Natural justice and procedural fairness

The principles of natural justice concern the general manner in which a decision is made. Essentially, procedural fairness does not concern the correctness of the decision. Rather, principles of natural justice help to ensure that the decision maker followed the proper procedure in arriving at their decision.

The principles of natural justice and procedural fairness are based on the theory that the substance of a decision is more likely to be fair if the procedure through which that decision was made has been just.

The applicant must be provided with an opportunity to present whatever evidence they wish to be considered.

While the right to be heard generally implies a hearing, it does not always mean an oral hearing. Submissions can be made in writing.

Opportunity to respond – When the decision maker is in possession of evidence not presented by the applicant, they must allow the applicant an opportunity to know and respond to that evidence.

Duty to consider all of the evidence – The decision maker is required to consider all of the relevant evidence and information pertaining to a specific case.

Right to impartial decision maker and freedom from bias – Procedural fairness is violated when the decision maker is biased or their conduct or statements raise a reasonable apprehension of bias.

An applicant has the right to a fair and impartial hearing and a fair and impartial decision maker. – Decision makers must not allow personal beliefs or interests to influence their decisions. The applicant does not have to prove that the decision maker was biased. The mere possibility of bias may be enough to show bias.

CANADIAN BILL OF RIGHTS

Part 1  –  1 (a)

Part 1  –  1 (b)

Part 1  –  2 (a)

Part 1  –  2 (b)

Part 1  –  2 (d)

Part 1  –  2 (e)

Part 1  –  2 (g)

RESIDENTIAL TENANCIES ACT, 2006

Part 12 – Appeal rights – 210. (1)

Part 12 – Powers of Court – 210. (4)

Part 12 – Same – 210. (5)

NATURAL JUSTICE

Right to Reasons

( EXHIBIT # 90 ) Upon reading the Appellants Factum supplied to the Divisional Courts by the Applicant. You will see the grounds for the appeal are as followed.

PART ONE

THE APPELLANT ALLISON READ APPEALS to the Divisional Courts from the judgement/order

( File: TEL – 83876 – 17 ) of Kevin Lundy dated October 3, 2017 made in/at Toronto East – RO, 2275 Midland Avenue, Unit 2, Toronto, Ontario, M1P 2E7. Regarding the rental unit at 303 – 859 Kennedy Road, Scarborough, Ontario, M1K 2E3.

PART TWO

Social Justice Tribunals Ontario Member Kevin Lundy made a serious error of law when creating his eviction order against the Appellant issued on under Section 68 – Residential Tenancies Act, 2006 dated October 3, 2017 ( File TEL – 83876 – 17 )

Social Justice Tribunals Ontario Member Kevin Lundy made a serious error of law against the Appellant by not following the intended spirt of the

  • Residential Tenancies Act, 2006
    • Constitution Act – Canadian Charter of Rights and Freedoms
    • Rights to Natural Justice
    • Canadian Bill of Rights

Social Justice Tribunals Ontario Member Kevin Lundy made a serious error of law against the Appellant when he denied the her, her rights to a fair and impartial hearing under the

  • Residential Tenancies Act, 2006
    • Constitution Act – Canadian Charter of Rights and Freedoms
    • Rights to Natural Justice
    • Canadian Bill of Rights

Social Justice Tribunals Ontario Member Kevin Lundy made a serious error of law against the Appellant when he did not follow and enforce the Appellants rights under the

  • Residential Tenancies Act, 2006
    • Constitution Act – Canadian Charter of Rights and Freedoms
    • Rights to Natural Justice
    • Canadian Bill of Rights

Social Justice Tribunals Ontario Member Kevin Lundy made a serious error of law when creating his eviction order against the Appellant that was made with a bias and prejudice.

PART THREE

Social Justice Tribunals Ontario Member Kevin Lundy seriously erred when providing inadequate written reasons in his order issued on under Section 68 – Residential Tenancies Act, 2006 dated October 3, 2017 ( File TEL – 83876 – 17 )

Social Justice Tribunals Ontario Member Kevin Lundy actions and lack of actions created a bias environment that was prejudice towards the Applicant which showed favouritism towards the Respondent.

Denied the Appellant her right to present her defense in full.

Denied the Appellant her right to present past negative conduct about Alto Properties Inc. and Stella Reddy.

Allowed the Appellant to hand in evidence relating to her Complaint dated October 31, 2017 but never gave her the opportunity to explain it.

This above action – c) – gave the Respondent an advance knowledge and insight into the Applicants Complaint and arguments dated October31, 2017.

Social Justice Tribunals Ontario Member Kevin Lundy decided that in the best interest of fair justice, he would not remand the hearing of September 26, 2017 to October 31, 2017 so they could be heard together.

Social Justice Tribunals Ontario Member Kevin Lundy at no time tried to correct Alto Properties Employee Stella Reddy behaviour or use of racially charged and prejudice language.

The decision by Social Justice Tribunals Ontario Member Kevin Lundy seriously erred as it is without adequate or sound reasons set out in his order, constitutes an error in the fact finding process.

Makes ruling based on only the Appellants past conduct since September 2015, but refused to hear or consider any negative past conduct of Stella Reddy and Alto Properties Inc.

Social Justice Tribunals Ontario Member Kevin Lundy does not consider the racially charge evidence handed in by Stella Reddy and Alto Properties Inc. in regards to motive for Respondents complaint.

Social Justice Tribunals Ontario Member Kevin Lundy does not consider Alto Properties Employee Stella Reddy behaviour, nor does he consider the use of racially charged and prejudice language during the trial.

Social Justice Tribunals Ontario Member Kevin Lundy verbal and lack of verbal actions resulted in him creating a bias environment that was prejudice towards the Applicant and it created favouritism towards the Respondent under the:

  • Residential Tenancies Act, 2006
    • Constitution Act – Canadian Charter of Rights and Freedoms
    • Rights to Natural Justice
    • Canadian Bill of Rights

Allow Alto Properties Inc. Employee Stella Reddy to make numerous derogator statements about New Foundlanders.

Allow Alto Properties Inc. Employee Stella Reddy to make a racially charged and prejudice statement that her “ NEPHEW IS AS BLACK AS YOU CAN GET ”

Allow Alto Properties Inc. Employee Stella Reddy to point at the Appellant while making a racially charge and prejudice comparison between her “ AS BLACK AS YOU CAN GET ” nephew and the Appellant.

Social Justice Tribunals Ontario Member Kevin Lundy at no time tried to verbally correct Alto Properties Inc. Employee Stella Reddy behaviour or use of racially charged and prejudice language.

Social Justice Tribunals Ontario Member Kevin Lundy physical actions resulted in him creating a bias environment that was prejudice towards the Applicant and it created a favouritism towards the Respondent under the:

  • Residential Tenancies Act, 2006
    • Constitution Act – Canadian Charter of Rights and Freedoms
    • Rights to Natural Justice
    • Canadian Bill of Rights

Social Justice Tribunals Ontario Member Kevin Lundy on two occasions made hand gestures to different fellow counsellors who were sitting in the gallery suggesting to“ HOLD ON ” and “ 1 MINUTE ” during the Appellants trial.

Social Justice Tribunals Ontario Member Kevin Lundy halted and disrupted the Appellants trial to allow for 3 fellow counsellors to “ PLAY THROUGH ”

RESIDENTIAL TENANCIES ACT, 2006

Part 1 – Purposes of Act – 1.

When Social Justice Tribunals Ontario Member Kevin Lundy created his order – He was not in accordance with the purposes/spirt of the Act by consciously not considering the Act as to provide protection for residential tenants from unlawful evictions and to provide for the ( fair ) adjudication of disputes and for other processes to informally resolve disputes.

Part 3 – Landlord’s responsibility to repair – 20. (1)

When Social Justice Tribunals Ontario Member Kevin Lundy created his order – He was not in accordance with the Act by consciously not considering the landlords responsible for providing and maintaining a residential complex, including the rental units in it, to maintain them is a good state of repair and fit for habitation and for complying with health, safety, housing and maintenance standards.

Part 3 – Landlord not to interfere with reasonable enjoyment – 22.

When Social Justice Tribunals Ontario Member Kevin Lundy created his order – He was not in

accordance with the Act by consciously not considering that the landlord cannot at any time during a tenant’s occupancy of a rental unit substantially interferes with the reasonable enjoyment of the rental unit.

Part 3 – Landlord not to harass, etc. – 23.

When Social Justice Tribunals Ontario Member Kevin Lundy created his order – He was not in accordance with the Act by consciously not considering the landlord, superintendent or agent of the landlord’s previous actions, harassment and racist behaviour towards the Applicant and her family.

Part 3 – Privacy – 25.

When Social Justice Tribunals Ontario Member Kevin Lundy created his order – He was not in accordance with the Act by consciously not considering the landlord, superintendent or agent of the landlord may only enter a rental unit only in accordance with section 26 or 27.

Part 3 – Entry With Notice – 27. (1) 4

When Social Justice Tribunals Ontario Member Kevin Lundy created his order – He was not in accordance with the Act by consciously not considering the landlord, superintendent or agent of

the landlord may only enter a rental unit only in accordance with section 26 or 27. Part 3 – Entry With Notice – 27. (1) 5

When Social Justice Tribunals Ontario Member Kevin Lundy created his order – He was not in accordance with the Act by consciously not considering the landlord, superintendent or agent of the landlord may only enter a rental unit only in accordance with section 26 or 27.

Part 3 – Tenant complaints – 29. (1) 1

When Social Justice Tribunals Ontario Member Kevin Lundy created his order – He was not in accordance with the Act by consciously not considering the Applicants complaint against the

landlord, superintendent or agent of the landlord. Part 3 – Tenant complaints – 29. (1) 3

When Social Justice Tribunals Ontario Member Kevin Lundy created his order – He was not in accordance with the Act by consciously not considering the landlord, superintendent or agent of the landlord has substantially interfered with the reasonable enjoyment of the rental unit or residential complex for all usual purposes by the tenant or a member of his or her household.

Part 3 – Tenant complaints – 29. (1) 4

When Social Justice Tribunals Ontario Member Kevin Lundy created his order – He was not in accordance with the Act by consciously not considering the landlord, superintendent or agent of the landlord has harassed, obstructed, coerced, threatened or interfered with the Applicant during the her occupancy of the rental unit.

Part 12 – Expeditious procedures – 183

When Social Justice Tribunals Ontario Member Kevin Lundy created his order – He was not in accordance with the Act by consciously used the “expeditious” rule as to allow him to create a bias environment that was prejudice towards the Applicant and it created favouritism towards the Respondent.

Part 12 – Board may mediate – 194. (1) (5)

When Social Justice Tribunals Ontario Member Kevin Lundy created his order – He was not in accordance with the Act by consciously using the “expeditious” rule, he did not allow the Applicant the opportunity to be fully heard or to present her full defense to the false allegations and claims.

Part 12 – Where Board may dismiss – 197. (1)

When Social Justice Tribunals Ontario Member Kevin Lundy created his order – He was not in accordance with the Act by consciously not considering the landlord, superintendent or agent of the landlord’s previous actions, harassment and racist behaviour towards the Applicant and her family.

Part 12 – Same (2)

When Social Justice Tribunals Ontario Member Kevin Lundy created his order – He was not in accordance with the Act by calculatedly not investigating and dismissing the Respondents complaint known contained false or misleading information.

Part 12 – Other powers of Board – 201. (1) (c)

When Social Justice Tribunals Ontario Member Kevin Lundy created his order – He was not in accordance with the Act by consciously not question any person, by telephone or otherwise, concerning the dispute.

Part 12 – Other powers of Board – 201. (1) (f).

When Social Justice Tribunals Ontario Member Kevin Lundy created his order – He was not in accordance with the Act by consciously not amending an Applicants complaint with the Respondents which allowed1 him to create a bias environment that was prejudice towards the Applicant and it created favouritism towards the Respondent.

Part 12 – Findings of Board – 202.

When Social Justice Tribunals Ontario Member Kevin Lundy created his order – He was not in accordance with the Act by calculatedly not trying to discover with certainty through examination or

experimentation the real substance of all transactions and activities relating to a rental unit and the good faith of the participants and in doing so,

Part 12 – Conditions in order – 204. (1)

When Social Justice Tribunals Ontario Member Kevin Lundy created his order – it was an intentional and premeditated attempt to deny and block the Applicant to her rights to be heard and have equal justice.

CANADIAN CHARTER OF RIGHTS AND FREEDOMS

Life, liberty and security of person – 7.

When Social Justice Tribunals Ontario Member Kevin Lundy created his order he calculatedly created it so it was an intentional and premeditated attempt to deny and block the Applicant to her rights to be heard and have equal justice. He was trying to deny the Applicant her right to life, liberty and security of the person and the right not to be deprived thereof except in accordance with the principles of fundamental justice.

Proceedings in criminal and penal matters – 11. (b)

When Social Justice Tribunals Ontario Member Kevin Lundy created his order he calculatedly created it so it was an intentional and premeditated attempt to deny and block the Applicant to her rights to be tried within a reasonable time.

Proceedings in criminal and penal matters – 11. (d)

When Social Justice Tribunals Ontario Member Kevin Lundy created his order he calculatedly created it so it was an intentional and premeditated attempt to deny and block the Applicant to her rights to be presumed innocent until proven guilty according to law in a fair and public hearing by an independent and impartial tribunal;

Treatment or punishment – 12.

When Social Justice Tribunals Ontario Member Kevin Lundy created his order he calculatedly created it so it was an intentional and premeditated attempt to deny and block the Applicant to her rights not to be subjected to any cruel and unusual treatment or punishment.

Interpreter – 14.

When Social Justice Tribunals Ontario Member Kevin Lundy created his order he calculatedly created it so it was an intentional and premeditated attempt to deny and block the Applicant to her right to speak the language in which the proceedings are conducted.

Equality Rights 15 – (1)

When Social Justice Tribunals Ontario Member Kevin Lundy created his order he calculatedly created it so it was an intentional and premeditated attempt to deny and block the Applicant to her right to equality before and under law and equal protection and benefit of law

Multicultural heritage – 27.

When Social Justice Tribunals Ontario Member Kevin Lundy created his order he calculatedly created it so it was an intentional and premeditated attempt to deny and block the Applicant to her right to a trail that was not interpreted in a manner consistent with the preservation and enhancement of the multicultural heritage of Canadians.

Rights guaranteed equally to both sexes – 28.

When Social Justice Tribunals Ontario Member Kevin Lundy created his order he calculatedly created it so it was an intentional and premeditated attempt to deny and block the Applicant to her rights and freedoms referred to in it are guaranteed equally to male and female persons.

NATURAL JUSTICE

When Social Justice Tribunals Ontario Member Kevin Lundy created his order where he errored in procedure that might have caused prejudice to a party.

When Social Justice Tribunals Ontario Member Kevin Lundy created his order that did not follow Natural justice as described as “fair play in action – the principles and procedures which in any particular situation or set of circumstances are right and just and fair” Its rules have been traditionally divided into two parts: Audi alteram partem – the duty to give persons affected by a decision a reasonable opportunity to present their case.

When Social Justice Tribunals Ontario Member Kevin Lundy created his order that did not follow Natural justice as described as “fair play in action – the principles and procedures which in any particular situation or set of circumstances are right and just and fair” Its rules have been traditionally divided into two parts: Nemo judex in causa sua debet esse ( No one should be a judge in his own case ) – the duty to reach a decision untainted by bias.

When Social Justice Tribunals Ontario Member Kevin Lundy created his order that did not follow Natural justice as described as an unreasonable exercise of discretion

When Social Justice Tribunals Ontario Member Kevin Lundy created his order that did not follow Natural justice as described as natural justice and procedural fairness

When Social Justice Tribunals Ontario Member Kevin Lundy created his order that did not follow Natural justice as described as the principles of natural justice concern the general manner in which a decision is made. Essentially, procedural fairness does not concern the correctness of the decision. Rather, principles of natural justice help to ensure that the decision maker followed the proper procedure in arriving at their decision.

When Social Justice Tribunals Ontario Member Kevin Lundy created his order that did not follow Natural justice as described as the principles of natural justice and procedural fairness are based on the theory that the substance of a decision is more likely to be fair if the procedure through which that decision was made has been just.

When Social Justice Tribunals Ontario Member Kevin Lundy created his order that did not follow Natural justice as described as the applicant must be provided with an opportunity to present whatever evidence they wish to be considered.

When Social Justice Tribunals Ontario Member Kevin Lundy created his order that did not follow Natural justice as described as while the right to be heard generally implies a hearing, it does not always mean an oral hearing. Submissions can be made in writing.

When Social Justice Tribunals Ontario Member Kevin Lundy created his order that did not follow Natural justice as described as an opportunity to respond – When the decision maker is in possession of evidence not presented by the applicant, they must allow the applicant an opportunity to know and respond to that evidence.

When Social Justice Tribunals Ontario Member Kevin Lundy created his order that did not follow Natural justice as described as duty to consider all of the evidence – The decision maker is required to consider all of the relevant evidence and information pertaining to a specific case.

When Social Justice Tribunals Ontario Member Kevin Lundy created his order that did not follow Natural justice as described as right to impartial decision maker and freedom from bias – Procedural fairness is violated when the decision maker is biased or their conduct or statements raise a reasonable apprehension of bias.

When Social Justice Tribunals Ontario Member Kevin Lundy created his order that did not follow Natural justice as described as an applicant has the right to a fair and impartial hearing and a fair and impartial decision maker. – Decision makers must not allow personal beliefs or interests to influence their decisions. The applicant does not have to prove that the decision maker was biased. The mere possibility of bias may be enough to show bias.

CANADIAN BILL OF RIGHTS

Part 1 – 1 (a)

When Social Justice Tribunals Ontario Member Kevin Lundy created his order he calculatedly created it so it was an intentional and premeditated attempt to deny and block the Applicant and her right to life, liberty, security of the person and enjoyment of property and the right not to be deprived thereof except by due process of law;

Part 1 – 1 (b)

When Social Justice Tribunals Ontario Member Kevin Lundy created his order he calculatedly created it so it was an intentional and premeditated attempt to deny and block the Applicant and her right to equality before the law and the protection of the law;

Part 1 – 2 (a)

When Social Justice Tribunals Ontario Member Kevin Lundy created his order he calculatedly created it so it was an intentional and premeditated attempt to deny and block the Applicant and her right to be exile.

Part 1 – 2 (b)

When Social Justice Tribunals Ontario Member Kevin Lundy created his order he calculatedly created it so it was an intentional and premeditated attempt to deny and block the Applicant and her right to not be a recipient of cruel and unusual treatment or punishment;

Part 1 – 2 (d)

When Social Justice Tribunals Ontario Member Kevin Lundy created his order he calculatedly created it so it was an intentional and premeditated attempt to deny and block the Applicant and her right to give evidence and/or protection against self – crimination or other constitutional safeguards;

Part 1 – 2 (e)

When Social Justice Tribunals Ontario Member Kevin Lundy created his order he calculatedly created it so it was an intentional and premeditated attempt to deny and block the Applicant and her right to not be deprived the right to a fair hearing in accordance to the principles of fundamental justice for the determination of his rights and obligations;

Part 1 – 2 (g)

When Social Justice Tribunals Ontario Member Kevin Lundy created his order he calculatedly created it so it was an intentional and premeditated attempt to deny and block the Applicant and her right to not be deprived the right to the assistance to an interpreter in any proceedings in which he is involved or in which he is a party or a witness, before a court, commission, board or other tribunal, if he does not understand or speak the language in which such proceedings are conducted.

PART FOUR

The law is created that the Applicant cannot be denied any of her rights under the;

  • Residential Tenancies Act, 2006
    • Constitution Act – Canadian Charter of Rights and Freedoms
    • Rights to Natural Justice
    • Canadian Bill of Rights

The conduct of Social Justice Tribunals Ontario Member Kevin Lundy clearly has infringed and denied the Applicant her guaranteed rights.

The Applicant also will enforce her CANADIAN CHARTER OF RIGHTS AND FREEDOMS – ENFORCEMENT OF GUARANTEED RIGHTS AND FREEDOMS / Exclusion of evidence bringing administration of justice into disrepute.

24. (1) Anyone whose rights or freedoms, as guaranteed by this Charter, have been infringed or denied may apply to a court of competent jurisdiction to obtain such remedy as the court considers appropriate and just in the circumstances.

  • (2) Where, in proceedings under subsection (1), a court concludes that evidence was obtained in a manner that infringed or denied any rights or freedoms guaranteed by this Charter, the evidence shall be excluded if it is established that, having regard to all the circumstances, the admission of it in the proceedings would bring the administration of justice into disrepute.

It is pretty straight forward and obvious that the Divisional Court will be dealing with only issue of bias and serious errors of law made by ONLY the Social Justice Tribunals Ontario Member Kevin Lundy.

Yes, the now alleged former Alto Properties Inc. Property Manager Stella Reddy used racially charged language, prejudice slurs and her own racially motivated actions during the hearing in front the Social Justice Tribunals Ontario Member Kevin Lundy.

And yes, the Social Justice Tribunals Ontario Member Kevin Lundy continued to allow the now alleged former Alto Properties Inc. Property Manager Stella Reddy to continuously use this inappropriate and unacceptable behaviour and then later tries to write them off as her being “ oblivious ” to her own ignorance to justify his illegal eviction order.

But still, the only questions that will NOT be in front of the Divisional Court is why did the now alleged former Alto Properties Inc. Property Manager Stella Reddy say or do what she did?

The only questions that will be in front of the Divisional Court will be;

  1. Why didn’t the Social Justice Tribunals Ontario Member Kevin Lundy not stop her?
    1. Why didn’t the Social Justice Tribunals Ontario Member Kevin Lundy not reprimand and/or correct her racially inappropriate and unacceptable behaviour?
    1. Why didn’t the Social Justice Tribunals Ontario Member Kevin Lundy deliberately ignore her racially charged language, prejudice slurs and her own racially motivated actions when making his illegal eviction Order?
    1. Why didn’t the Social Justice Tribunals Ontario Member Kevin Lundy deliberately deny the Applicant all her rights under
      1. Residential Tenancies Act, 2006
      1. Constitution Act – Canadian Charter of Rights and Freedoms
      1. Rights to Natural Justice
      1. Canadian Bill of Rights

“ [7] There is no information before the Tribunal to indicate that proceeding with the human rights Complaints would create a real risk of inconsistent decisions on the factual or legal issues raised in the Complaints. In the absence of such risk, deferring the Complaints would be inconsistent with the Tribunal’s mandate of ensuring the fair, just and expeditious resolution of Complaints. ”

“ [6] Given the distinct nature of the issues before the Tribunal and the SBT, it is not appropriate to defer the Complaint. In my view, the reason for deferring an Complaint – avoiding inconsistent findings of fact or law by adjudicators in concurrent proceedings – does not exist where there is no ongoing proceeding before the SBT with respect to the subject – matter of the Complaint. ”

The Divisional Court will only be dealing and making a finding in regards to the behaviour and obvious bias that the Social Justice Tribunals Ontario Member Kevin Lundy had against the Applicant with his illegal eviction order.

The Applicants take the position that the factual and legal issues in the Divisional Court and the LTB hearing are clearly and obviously distinctly different from the complaints in the HRTO against the 3 Respondents.

The Divisional Court proceedings will not address any of the issues filed with the HRTO about the harassing, discriminating and acting in a reprisal manner against the Applicants by the 3 respondent.

This means that there is NO LEGAL GROUNDS to defer and/or dismiss the complaints and despite the fact that everything may be running concurrently, there is no possibility of inconsistent FINDINGS ON FACTS OF LAW between the Divisional Court and the HRTO or that of the LTB.

And despite the Divisional Court might hear some of the same facts, might see some of the same documents. In the end the only goal of Divisional Court is to make a finding in regards to Social Justice Tribunals Ontario Member Kevin Lundy and his illegal behaviour against the Applicants.

The Divisional Court will not be making any findings in regards to any of the her racially charged language, prejudice slurs, racially motivated actions of harassment, discriminating and acting in a reprisal manner complaints filed with the HRTO against the 3 Respondents.

9

REMEDIES

( EXHIBIT # 93 ) LTB hearing – September 26, 2017 – Initiated by the 3 Respondents this had nothing to do with the Applicants. The remedies sought are by the 3 Respondents on September 26, 2017 and it had nothing to do with their harassment and racist motivated behaviour towards of the Applicants.

The 3 Respondents requested remedy was to end Applicants tenancy.

LTB hearing – October 31, 2017 – Initiated by the Applicants, but never proceeded forward as they withdrew the complaint on the date of hearing without prejudice, as the outcome of this hearing would have played no factor is in the illegal evection notice by the Social Justice Tribunals Ontario Member Kevin Lundy dated October 3, 2017.

The fact is that the LTB never heard this complaint, nor did they make any finding in regards to it.

The LTB was never given any document or heard any arguments in regards to this complaint. Meaning that Divisional Court cannot hear this complaint as it was not part of original hearing on September 25, 2017 in front of the Social Justice Tribunals Ontario Member Kevin Lundy.

Therefore this application that was withdrawn has no role or place in the Applicants HRTO complaints, Divisional Court or LTB hearing against the 3 Respondents. The Applicants basically withdrew the complaint and essentially freeing them up to proceed to the HRTO.

( EXHIBIT # 94 ) Divisional Court Notice Of Appeal – October 24, 2017 – Initiated and filed by the Applicants. The remedies requested are;

In line # 2, the Applicant requested to Divisional Court “ The Appeals Court hear file TEL – 83876 – 17. From the Social Justice Tribunals Ontario and make a ruling in favor of the Appellant(s) ”

At the time of filing the Applicants were working with a very tight deadline to file with Divisional Court and had no idea how the Appeal Process worked. They subsequently filled out the Appeals Form with no help from any Legal Support Centers as they found the case to be too complex and lengthy to deal with.

At the time of filing, the Applicants had no idea what the jurisdiction or powers of the Divisional Court were, and basically had to put together a Notice of Appeal on their own the best they could.

It was not until after the Appeal was perfected that they began to fully understand what could and could not be argued in Divisional Court.

The Applicants placed as much information as they could in an attempt to protect their rights to argue issues in Divisional Court. They did not want to eventually get in front of the 3 judge panel and be told that since there was no mention in the documents about a specific topic, they were excluded from raising the issue.

( EXHIBIT # 95 ) Divisional Court Appellant Factum – Initiated by the Applicant. You can clearly see that the only remedies requested are that for illegal eviction order by the Social Justice Tribunals Ontario Member Kevin Lundy.

Again, at the time of filing the Applicants were working with a very tight deadline to file the document and had no idea how the appeal process worked. They subsequently completed the Appellant Factum with no help from any Legal Support Centers as they found the case to be too complex and lengthy to deal with.

At the time of filing, the Applicants had no idea what the jurisdiction or powers of the Divisional Court were, and basically had to put together a Appellant Factum on their own the best they could.

The Applicants at that time had no idea that the Divisional Court could not hear the case that was presented to the LTB. That the Divisional Court could only hear about issue of error in law. So their request for a new hearing in front of the Divisional Court was a request that cannot be fulfilled as the documents itself is not in dispute. It is the conduct and bias of the Social Justice Tribunals Ontario Member Kevin Lundy.

“ If not, The Applicant is asking that the panel find that the judgement/order ( File: TEL – 83876 – 17 ) of Kevin Lundy dated October 3, 2017 made in/at Toronto East – RO, 2275 Midland Avenue, Unit 2, Toronto, Ontario, M1P 2E7.

Regarding the rental unit at 303 – 859 Kennedy Road, Scarborough, Ontario, M1K 2E3 was made in error and both the Applicant and the Respondents evidence is heard in full by the panel and a new finding is made. ”

Again it was not until after the appeal was perfected, that they began to fully understand what could and could not be argued in Divisional Court.

Again the Applicants placed as much information as they could in an attempt to protect their rights to argue issues in Divisional Court. They did not want to eventually get in front of the 3 judge panel and be told that since there was no mention in the documents about a specific topic, they were excluded from raising the issue.

( EXHIBIT # 93, 94, 95 ) So reviewing the;

·         3 Respondents LTB complaint on September 26, 2017

  • Applicants LTB complaint on October 31, 2017

·         Divisional Court Notice of Appeal

  • Divisional Court Appellant Factum

It is clear and obvious that the remedies in each case do not meet the threshold to be considered the same remedies that are being requested by the Applicants in the HRTO.

The Applicants may have requested similar remedies in part for October 31, 2017, but the LTB never heard their complaints and the Divisional Court does not have the jurisdiction or power to grant the Applicants the remedy they original requested.

If it comes to be learned that for some strange reason the Divisional Court can hear about the documents in regards to the HRTO. The remedies are still different.

The Applicants are asking the Divisional Court to ONLY deal with the eviction order and NOT the racially motivated actions of harassment, discriminating and acting in a reprisal manner against the Applicants by the 3 Respondents.

The Applicant is seeking no remedies from the Human Rights Code for their racially motivated actions of harassment, discriminating and acting in a reprisal manner against the Applicants by the 3 Respondents, nor do they intend to in Divisional Court.

It is also the Applicants position that the now alleged former Alto Properties Inc. Property Manager Stella Reddy has deliberately made absolutely no arguments, quoted or presented any legal grounds in her written response to this issue.

It is the Applicants position that Alto Properties Inc. Property Manager Stella Reddy has chosen to forfeit her right to have any place at the table to argue any issues relating to remedies, as she has deliberately not presented any documents or argument to collaborate and justify her request for a deferral and/or dismissal that she has requested.

It is the Applicants position that Alto Properties Inc. Property Manager Stella Reddy has taken it upon herself to not present the required documents to collaborate or justify her request for deferral and/or dismissal.

The now alleged former Alto Properties Inc. Property Manager Stella Reddy willfully and without any threats of reprisal, violence, repercussions or intimidation decided that she was not going to address the issue of deferral and/or dismissal that was requested by her in her response.

It appears that the now alleged former Alto Properties Inc. Property Manager Stella Reddy thinks that it is the HRTO responsibility and obligation to make her positions fully known, or to create an argument on her behalf and to present documents that help justify her own request for a deferral and/or dismissal.

It is Applicants position that this is not the case, and that the now alleged former Alto Properties Inc. Property Manager Stella Reddy should not have placed these inappropriate expectations upon HRTO, as it is solely HER responsibility to present, validate and defend her own request for deferral and/or dismissal.

It is the Applicants position that Alto Properties Inc. owner Luigi Liscio and Alto Properties Inc. owner Anthony Liscio have chosen to forfeit their right to have any place at the table to argue any issues relating to remedies for a deferral and/or dismissal, as they have deliberately not provide a physical copy or digital copy of their authorities, present explanations about their authorities that are so vaguely explained or in some cases lack any type of explanation at all to justify their request for a deferral and/or dismissal that they had requested.

It is the Applicants position that Alto Properties Inc. owner Luigi Liscio and Alto Properties Inc. owner Anthony Liscio have taken it upon themselves to deliberately not present the required documents to collaborate or justify their request for deferral and/or dismissal.

Alto Properties Inc. owner Luigi Liscio and Alto Properties Inc. owner Anthony Liscio willfully and without any threats of reprisal, violence, repercussions or intimidation decided that they were not going to address some issue raised in their request for deferral and/or dismissal that was requested by them in their response.

It appears that Alto Properties Inc. owner Luigi Liscio and Alto Properties Inc. owner Anthony Liscio think that it is the HRTO responsibility and obligation to make their positions fully known, or to create an argument on their behalf and to present documents that help justify their own request for a deferral and/or dismissal.

It is Applicants position that this is not the case, and that Alto Properties Inc. owner Luigi Liscio and Alto Properties Inc. owner Anthony Liscio should not have placed these inappropriate expectations upon HRTO, as it is solely THEIR responsibility to present, validate and defend their own request for deferral and/or dismissal.

It is the position of the Applicants that due to the inadequate responses by the 3 Respondents, it is clear that they are relying solely upon the fact that there are two legal proceedings ongoing to justify having the complaints by the Applicants to be deferred and/or dismissed. It has been acknowledged in numerous authorities that a deferral is not simply invoked simple because the same factual circumstances arise in other ongoing legal proceedings.

10

1-YEAR (ONE) YEAR LIMITATION PERIOD

Complaint by person

34 (1) If a person believes that any of his or her rights under Part I have been infringed, the person may apply to the Tribunal for an order under section 45.2,

  • if there was a series of incidents, within one year after the last incident in the series.

The 3 Respondents have deliberately made absolutely no arguments, quoted or presented any legal grounds in her written response as to why the complaints against them should be deferred and/or dismissed at their own request.

It is the Applicants position that the 3 Respondents have chosen to forfeit their rights to have any place at the table to argue any issues relating 1 ( one ) year limitation period, as they have deliberately not presented any documents or argument to collaborate and justify their request for a deferral and/or dismissal that they has requested.

It is the Applicants position that the 3 Respondents have taken it upon themselves to not present the required documents to collaborate or justify their request for deferral and/or dismissal.

The 3 Respondents willfully and without any threats of reprisal, violence, repercussions or intimidation decided that they were not going to address the issue of 1 year time limitation in their request deferral and/or dismissal by them in their response.

It appears that the 3 Respondents think that it is the HRTO responsibility and obligation to make their positions fully known, to create an argument on their behalf and to present materials that help justify their own request for a deferral and/or dismissal.

It is Applicants position that this is not the case, and that the 3 Respondents should not have placed these inappropriate expectations upon HRTO, as it is solely THEIR responsibility to present, validate and defend their own request for deferral and/or dismissal.

The Applicants take the position that because 3 Respondents requested the deferral and/or dismissal based the submission that a substantial number of allegations fall outside the 1 (one) year limitation period is completely inaccurate and ambiguous..

The Act makes it very clear that – if there was a series of incidents, within one year after the last incident in the series.

As the 3 Respondents have decided to deliberately not elaborate on this issue, the Applicants are very puzzled as to their grounds and what time frame they think they are working with.

A quick review of the document provided by the Applicants, the harassing, discriminating and acting in a reprisal behaviour against the Applicants by 3 Respondents has been ongoing since the obvious meeting in June 2016, August 2016, October 2016, August 2017, September 2017, October 2017, March 2018 and June 2018.

( EXHIBIT # 96 )

( EXHIBIT # 23 ) Just by reviewing the Applicants 107 Statement of Facts provided, it is pretty obvious the 3 Respondents have been harassing, discriminating and acting in a reprisal manner against the Applicants since the now alleged former Alto Properties Inc. Property Manager Stella Reddy meeting in June 2016.

Given the obvious illegal N5’s given to the Applicants, the denying the Applicants parking privilege despite giving other tenants the same parking privileges, there deliberately actions to inconvenience the Applicants, alter documents to justify an illegal N5 and the numerous amounts of lies over and over that have been proven that cannot be disputed .

( EXHIBIT # 97 ) Even the Social Justice Tribunals Ontario Member Kevin Lundy address the illegal N5’s created by the 3 Respondents in his illegal eviction order of October 03, 3017 against the Applicants.

“ Although some of Stella Reddy’s past notices of entry were provided in less than 24 hours of the time of entry ”

Even the Social Justice Tribunals Ontario Member Kevin Lundy noticed the behaviour of the now alleged former Alto Properties Inc. employee Stella Reddy through her own words and actions. There can be no more doubt that the 3 Respondents were harassing, discriminating and acting in a reprisal manner continuously since 2016.

11

ABSOLUTE PRIVILEGE

Again the now alleged former Alto Properties Inc. employee Stella Reddy offered a lengthy 12,620 word/16 page response to the HRTO, which included numerous pictures. In her 16 page response, she decides that she does not need to address the issue of Absolute Privilege, but instead focusses on being more concerned about examining the irrelevant issues of;

1.                 How bad the Applicants are.

  • Her and her husband’s previous employment and living history.

3.                 All of her and her husband’s past and present finical difficulties.

  • How the Applicants and 3 other units start a tenant association.

5.                 Her experience in a house fire.

  • Her past and current metal health issues.

7.                     Her past and current history of physical injuries.

  • The current state of her mother’s health problems.

9.                 Explaining what Psychosis is.

  1. How the Applicants will most certainly lose in Divisional Court.

11.             Her transgender son’s personal battles and history.

  1. Her other son and his history with Attention Deficit Disorder when he was 4 years old.

13.             Her other son and his fiancé who is from Chile.

  1. How she was a single mother.

No matter how times the Applicants read the now alleged former Alto Properties Inc. employee Stella Reddy 16 page response given to the HRTO. They can make absolutely no connection between above irrelevant issues and the HRTO complaints against her, and absolute privilege.

It is the Applicants position that the now alleged former Alto Properties Inc. Property Manager Stella Reddy has deliberately made absolutely no arguments, quoted or presented any legal grounds in her written response to this issue.

It is the Applicants position that Alto Properties Inc. Property Manager Stella Reddy has chosen to forfeit her right to have any place at the table to argue any issues relating to absolute privilege, as she has deliberately not presented any documents or argument to collaborate and justify her request for a deferral and/or dismissal that she has requested.

It is the Applicants position that Alto Properties Inc. Property Manager Stella Reddy has taken it upon herself to not present the required documents to collaborate or justify her request for deferral and/or dismissal.

The now alleged former Alto Properties Inc. Property Manager Stella Reddy willfully and without any threats of reprisal, violence, repercussions or intimidation decided that she was not going to address the issue of deferral and/or dismissal that was requested by her in her response.

It appears that the now alleged former Alto Properties Inc. Property Manager Stella Reddy thinks that it is the HRTO responsibility and obligation to make her positions fully known, or to create an argument on her behalf and to present documents that help justify her own request for a deferral and/or dismissal.

It is Applicants position that this is not the case, and that the now alleged former Alto Properties Inc. Property Manager Stella Reddy should not have placed these inappropriate expectations upon HRTO, as it is solely HER responsibility to present, validate and defend her own request for deferral and/or dismissal.

have chosen to forfeit their right to have any place at the table to argue any issues relating to absolute privilege for a deferral and/or dismissal, as they have deliberately not provide a physical copy or digital copy of their authorities, present explanations about their authorities that are so vaguely explained or in some cases lack any type of explanation at all to justify their request for a deferral and/or dismissal that they had requested.

It is the Applicants position that Alto Properties Inc. owner Luigi Liscio and Alto Properties Inc. owner Anthony Liscio have taken it upon themselves to deliberately not present the required documents to collaborate or justify their request for deferral and/or dismissal.

Alto Properties Inc. owner Luigi Liscio and Alto Properties Inc. owner Anthony Liscio willfully and without any threats of reprisal, violence, repercussions or intimidation decided that they were not going to address some issue raised in their request for deferral and/or dismissal that was requested by them in their response.

It appears that Alto Properties Inc. owner Luigi Liscio and Alto Properties Inc. owner Anthony Liscio think that it is the HRTO responsibility and obligation to make their positions fully known, or to create an argument on their behalf and to present documents that help justify their own request for a deferral and/or dismissal.

It is Applicants position that this is not the case, and that Alto Properties Inc. owner Luigi Liscio and Alto Properties Inc. owner Anthony Liscio should not have placed these inappropriate expectations upon HRTO, as it is solely THEIR responsibility to present, validate and defend their own request for deferral and/or dismissal.

Upon reading the documents supplied by the Applicants to the Divisional Court. It is clear and obvious that the entire appeal is based on the conduct of the Social Justice Tribunals Ontario Member Kevin Lundy.

The 3 Respondents are now so irrelevant to the appeal that they will not even have to speak in regards to their harassing, discriminating and acting in a reprisal manner against the Applicants.

This fact made by the Applicants is again confirmed by the now alleged former Alto Properties Inc. Property Manager Stella Reddy in an email to the HRTO on December, 9, 2018 at 14:37.

( EXHIBIT # 98 ) She states that the Divisional Court complaint has nothing to do with her that I don’t have anything to do with it anymore and I don’t even need to show up to the hearing

It is also pretty clear and obvious that the now alleged former Alto Properties Inc. Property Manager Stella Reddy was not acting in any legal capacity or as counsel for Alto Properties Inc. owner Luigi Liscio and Alto Properties Inc. owner Anthony.

The now alleged former Alto Properties Inc. Property Manager Stella Reddy does not hold any legal standing with the Law Society of Ontario or anywhere in Canada and therefore cannot practice law, and therefore she cannot be considered counsel for Alto Properties Inc. owner Luigi Liscio and Alto Properties Inc. owner Anthony.

cannot claim any rights to absolute privilege, as the now alleged former Alto Properties Inc. Property Manager Stella Reddy was not working in a legal capacity or as counsel for them.

Reviewing the transcripts and listening to the recording from the LTB hearing on September 26, 2018. There can be no arguments that it was in fact the now alleged former Alto Properties Inc. Property Manager Stella Reddy using all racially charged language, prejudice slurs and racially motivated actions at the LTB hearing.

But amazingly Alto Properties Inc. owner Luigi Liscio and Alto Properties Inc. owner Anthony Liscio are trying to claim/piggy back their absolute privilege on the behalf of the their alleged former Alto Properties Inc. Property Manager Stella Reddy.

The question is how can another Respondent(s) claim/piggy back absolute privilege on the behalf of someone who did all the talking and does not qualify as legal counsel for them?

( EXHIBIT # 99 )

“ [14] [90] Absolute privilege is a common law principle which, among other things, prohibits legal proceedings which are based on statements made by legal counsel while representing their clients in respect of ongoing or contemplated judicial or quasi – judicial proceedings. ”

It is the position of the Applicants that Alto Properties Inc. owner Luigi Liscio and Alto Properties Inc. owner Anthony Liscio cannot claim absolute privilege on behalf of a 3rd parties behaviour when it is not their legal counsel.

The HRTO has to conclude that it is the responsibility of the independent wrongdoer to request absolute privilege on their own behalf and not the responsibility of other Respondents in separate complaints.

The HRTO has to remember that they requested and asked the Applicants consolidate 4 months ago.

At the time of filing their responses Alto Properties Inc. owner Luigi Liscio and Alto Properties Inc. owner Anthony Liscio had 2 different HRTO complaints against them.

  • 2018 – 32808 –
  • 2018 – 32810 –

And there were 2 separate and independent HRTO complaints against the other single Respondent the now alleged former Alto Properties Inc. employee Stella Reddy.

  • 2018 – 32809 –
  • 2018 – 32811 –

Essentially they were 2 different groups of Respondents in 4 different cases. The HRTO complaints could proceed as two different hearings on two different days.

And at the time of filing this Reply, the situation had not changed and therefore it is the Applicants position that Respondents from HRTO complaints 2018 – 32808 –  , 2018 – 32810 –  cannot request absolute privilege off of and/or on the behalf of the Respondent from separate complaints. 2018 – 32809 – , 2018 – 32811 –

The HRTO has a very long and well documented history of stating that absolute privilege cannot be the BASIS of a complaint.

It is Applicants position that the racially charged language and prejudice slurs and actions by the now alleged former Alto Properties Inc. Property Manager Stella Reddy are not to be considered absolute privilege as they are NOT THE BASIS of the complaints filed against the 3 Respondents.

It is the Applicants position that despite absolute privilege being invoked, the law clearly and obvious states that it can be used as long as IT IS NOT THE BASIS of the complaint.

Basis is defined as:

  • Anything upon which something is based, fundamental principle; groundwork.

Looking at all the document that has been provided by the Applicants it is pretty obvious that the racially charged language and prejudice slurs and actions by the now alleged former Alto Properties Inc. Property Manager Stella Reddy are not and do not need to be the BASIS of the complaints filed against the 3 Respondents.

( EXHIBIT # 100 )

“ [5] Comments made in a court proceeding by one party about the other party have been found to be protected by absolute privilege and that such comments cannot be used as a basis for an Complaint under the Human Rights Code

“ [7] the Tribunal’s case law is clear that such comments are privileged, and CANNOT be used as THE BASIS for an Complaint under the Code ”

( EXHIBIT # 101 ) But reviewing the finding by the Social Justice Tribunals Ontario Member Jo – Anne Pickel in Donald Williams – VS – TTC, Lori MacGregor, Nick Valente, Amaigamated Trans Union and Local 113.

“ [38] Second, the cause of action in this case is NOT FOUNDED upon the statements. Instead, the applicant seeks to rely upon the statements as evidence to support his claim of discrimination and reprisal. ”

It is clear that the Applicants are not relaying on the now alleged former Alto Properties Inc. Property Manager Stella Reddy racially charged language and prejudice slurs as the foundation/basis of their complaints against the 3 Respondents and their harassing, discriminating and acting in reprisal behaviour.

As in Donald Williams – VS – TTC, Lori MacGregor, Nick Valente, Amaigamated Trans Union and Local 113 case. The Applicants are only wishing to use the obvious racially charged language and prejudice slurs to support their claims against the 3 Respondents.

Despite the fact the now alleged former Alto Properties Inc. Property Manager Stella Reddy used obvious racially charged language and prejudice slurs in a public forum. That is her right to do so under the Canadian Charter of Rights and Freedoms.

These Rights and Freedoms guarantee her the freedom of thought, belief, opinion and expression, including freedom of the press and other media of communication.

This same luxury that is afforded to the now alleged former Alto Properties Inc. Property Manager Stella Reddy is also given to people like the woman who went on racist rant at a Mississauga doctor’s clinic openly demanding she wanted to see only a white doctor back in June 2017.

It is also afforded to people like Peter Simpson from Calgary, Lombray Ball of Toronto and Rachelle Elsiufi from Edmonton to be free of any direct prosecution relating directly to their racist rants itself.

Social Justice Tribunals Ontario Member Mary Truemner admits that “ The courts have often recognized that the immunity from litigation afforded by absolute privilege does not exist to protect the wrongdoer, but it will sometimes do so. ”

( EXHIBIT # 102 ) But regardless of this obvious error in law within our system, a liberal Social Justice Tribunals Ontario Member Sophie Martel has now taken a new approach to correct this imperfection.

Social Justice Tribunals Ontario Member Sophie Martel stated “ [11] a statement WILL NOT BE PROTECTED it if is not uttered for the purposes of judicial proceedings by someone who has a duty to make statements in the course of

the proceedings. ”

Let us note that this finding was made in February 27, 2018 of this year that recognizes the obvious flaw in the system. And she has finally taken the initiative to balance out the scales of fair justice.

The point behind this finding is to hold people accountable for unnecessary and defamatory statements in Ontario Tribunals that are only uttered out of vindictiveness and/or an attempt to embarrass another party about their;

  • Race
  • Colour
  • Ancestry
  • Place of origin
  • Citizenship
  • Ethnic origin
  • Disability
  • Creed
  • Sex, including sexual harassment and pregnancy
  • Sexual orientation
  • Gender identity
  • Gender expression
  • Family status
  • Marital status
  • Age
  • Receipt of public assistance
  • Record of offences

This finding certainly applies to now alleged former Alto Properties Inc. Property Manager Stella Reddy as her racially charged language, prejudice slurs and her own racially motivated actions in a public forum at the LTB hearing on September 26, 2017 had nothing to do with the 3 Respondents filing for Refusal of Entry.

There was absolutely no reason for now alleged former Alto Properties Inc. Property Manager Stella Reddy to try and justify her racist beliefs as legal the only issue before the LTB was did the Applicants refuse her entry, YES OR NO?

The now alleged former Alto Properties Inc. Property Manager Stella Reddy may have wanted to discuss the conversation that transpired between the Applicants. But in actuality all she had to do was state

I gave proper Notice and I was refused.. Done…

The Act is very clear about that.

There was absolutely no reason for her to bring up what happened or what was said. It had absolutely nothing to do with…

DID THE APPLICANTS ALLOW YOU IN YES OR NO?

Again there was no need for now alleged former Alto Properties Inc. Property Manager Stella Reddy to utter the slur

“ Newfie ” numerous times in front of the Applicants, arbitrator and public.

The now alleged former Alto Properties Inc. Property Manager Stella Reddy may have wanted to discuss this topic, but in actuality all she had to do was state

I gave proper Notice and I was refused.. Done…

The Applicants found the now alleged former Alto Properties Inc. Property Manager Stella Reddy prejudice slurs offensive about New Foundlanders and to be unwanted harassment, despite it not being directly towards them.

The Applicants position is that a person does not have to possess a certain characteristic themselves for it to be considered unwanted harassment.

Again there was no need for the now alleged former Alto Properties Inc. Property Manager Stella Reddy to say the racially charged “ Mullato ” statement towards and in the presence of their children again.

The now alleged former Alto Properties Inc. Property Manager Stella Reddy may have wanted to discuss this topic, but in actuality all she had to do was state

I gave proper Notice and I was refused.. Done…

The now alleged former Alto Properties Inc. Property Manager Stella Reddy statement was insensitive and shameful and it is classified as harassment.

Again the racially motivated conduct the now alleged former Alto Properties Inc. Property Manager Stella Reddy was unwanted and not needed in a public LTB hearing.

This was the 2nd time the now alleged former Alto Properties Inc. Property Manager Stella Reddy had referred to the Applicants children as “ Mullato ” in their presence and in a public area.

The Applicants wants to remind the HRTO the racial charged slur “ Mulatto ” is a considered a derogatory term by society, because came into use during slavery when referring to the bi-racial offspring of African slaves and most often their white European slave masters.

The now alleged former Alto Properties Inc. Property Manager Stella Reddy also stated my “ I have very beautiful great nephews and nieces who are half black, and my nephew is as black as you can get. He’s even darker than she is. ”” while point at the Applicant, embarrassing and shaming her about her complexion.

Again all the now alleged former Alto Properties Inc. Property Manager Stella Reddy may have wanted to discuss this topic, but in actuality all she had to do was state

I gave proper Notice and I was refused.. Done…

But instead the now alleged former Alto Properties Inc. Property Manager Stella Reddy wanted to either imply to Applicant that despite her great “ nephew ” being even “ darker than she is ” that he is still beautiful.

So one has to wonder if her great nephew had a lighter complexion than the Applicant, would she still think he is as beautiful?

Did the now alleged former Alto Properties Inc. Property Manager Stella Reddy also mean to imply to the Applicant

The real irony of this whole racially charged language and actions “ He’s even darker than she is. ” that were made by the now alleged former Alto Properties Inc. Property Manager Stella Reddy in perjury at the LTB hearing. Is that her great nephew has a far lighter complexion than the Applicant herself.

So now that it has been confirmed that her great nephew has a lighter complexion than the Applicant. Does she really still think he is more beautiful than when he was untruthfully darker?

So what was the motive behind the now alleged former Alto Properties Inc. Property Manager Stella Reddy making this racially charged deliberately misleadingly derogatory statement?

Does the now alleged former Alto Properties Inc. Property Manager Stella Reddy believe that by committing perjury, using racially charged language and prejudice slurs and actions in a public forum proves that she is not a racist?

How does her nieces and nephews having children with individuals that have a different skin complexion make her not a racist?

The facts are that the now alleged former Alto Properties Inc. Property Manager Stella Reddy has no control over whom her nieces and nephews date and who the decided to have children with!

It is the position on the Applicant that any perjury that is committed in the act of a legal proceeding is not covered by absolute privilege because it is uttered with malice and intent to deceive the system.

The topic that now alleged former Alto Properties Inc. Property Manager Stella Reddy lied and committed perjury about was not a topic relating to the Entry of Refusal.

And the lie and perjury itself that was committed by the now alleged former Alto Properties Inc. Property Manager Stella Reddy is not a topic of the Refusal of Entry itself.

They only way it could be considered absolute privilege is to say that lie and perjury were part of the hearing in some strange way. The fact that the now alleged former Alto Properties Inc. Property Manager Stella Reddy lied and committed perjury does not absolve her of absolute privilege any more under Social Justice Tribunals Ontario Member Sophie Martel.

It was the now alleged former Alto Properties Inc. Property Manager Stella Reddy who was the first person use racially charged language and prejudice slurs at the LTB hearing on September 26, 2017.

It is the Applicants position that none of it had any relevance or purpose at the LTB hearing for their request for an eviction order for Refusal of Entry by the 3 Respondents.

The questions here is what was real reason behind the now alleged former Alto Properties Inc. Property Manager Stella Reddy sudden mysterious use of all this racially charged language and prejudice slurs and actions in a public forum at the LTB hearing?

What was real reason behind the now alleged former Alto Properties Inc. Property Manager Stella Reddy filing all the letters from the Applicants where they called her out about her racist behaviour from a year earlier?

( EXHIBIT # 103 ) It almost appears that the now alleged former Alto Properties Inc. Property Manager Stella Reddy was coached, maybe by some familiar with the law to come into the LTB hearing and to file these irrelevant letters, use irrelevant racially charged language and irrelevant prejudice slurs as to try and provoke a response from the

“ BLACK ” Applicant and her husband?

Afterwards the now alleged former Alto Properties Inc. Property Manager Stella Reddy would use the Applicants provoked frustration to justify the harassment and racist motivated behaviour towards them in small claims court which she intend to file.

Was she thinking that her racially charged language and prejudice slurs and actions could not be used against her, because she was coached, maybe by some familiar with the law into believing that it would qualify as absolute privilege?

It would have been a win, win, win and win for the now alleged former Alto Properties Inc. Property Manager Stella Reddy in her mind.

( win #1 ) She could provoke a negative response from the Applicants, ( win #2 ) use it against them in the LTB hearing, (win #3) and in Small Claims Court, and ( win #4 ) there is nothing the Applicants could do about it, as she believed it would be covered by absolute privilege.

Then there is the possibility that the now alleged former Alto Properties Inc. Property Manager Stella Reddy thought that being able to claim absolute privilege in a judicial proceeding. She could now use absolute privilege to thwart any attempts of future HRTO complaints or document from being submitted against her in regards to her harassing, discriminating and acting in a reprisal manner towards the Applicants.

( EXHIBIT # 104 ) In fact she openly stated in Letter 303.docx, an email attachment on June 09, 2017 that “ no one will give a shit ” about her boorish way of thinking.

“ There was no bias, no one will give a shit what I said out of frustration over your lies, as in the end, it was what you did that got you evicted! My reaction is a normal human reaction to hearing details of a lie you perpetuated to base your accusations on and as you seem to be continually keeping it up, without even proof that this even happened, is harassment as defined by the Human Rights ”

( EXHIBIT # 105 ) In fact she again openly stated in an August 15.docx email attachment on August 14, 2018 that “ no one will give a shit ” about her boorish way of thinking.

“ The hearing was very frustrating due to the constant accusations of racism I received about this alleged conversation so in my frustration I did say that my nephew in law was as black as black. I also stated I am a Newfie and yet Mr. Read makes it sound like “Newfie” is a slur. ”

( EXHIBIT # 106 )

“ Yes, they are my words and yes, its recorded but you can also hear the shock and confusion when I am speaking. That is also important. I have no problem with it and you can do what you wish as everyone will see through your actions, as always. The LTB knew why I said that, as it is pointed out in the eviction notice, that it was said out of shock after hearing what I did for the first time. It is human nature and anyone and everyone can understand my reaction. I have no problem admitting this and I did so in my response, I have been told that what I said is mild compared to something I could have said if I was an actual racist and thought like one. Some of the things I heard that could have been said is not fit to repeat. As I am not racist and don’t think that way, this is what came out when you were stating your lies over this alleged meeting. Go right ahead and turn it into what you want people to see ”

It appears that even to this very day the now alleged former Alto Properties Inc. Property Manager Stella Reddy still refuses to admit that the a majority of society does not think the way she does, or at least openly admit to it.

It is amazing how the now alleged former Alto Properties Inc. Property Manager Stella Reddy encourages the Applicants to tell others of her racially charged language and prejudice slurs and actions from the LTB hearing, as it is some kind of banner that people will champion behind.

It is perplexing to the Applicants as to why the now alleged former Alto Properties Inc. Property Manager Stella Reddy thinks her racially charged language and prejudice slurs and actions are acceptable at any level?

Does the now alleged former Alto Properties Inc. Property Manager Stella Reddy really think that the HRTO or anyone else would buy into her racially charged language and prejudice slurs and actions at the LTB as being considered as

“ human nature ”?

The now alleged former Alto Properties Inc. Property Manager Stella Reddy goes on to state “ I have been told that what I said is mild compared to something I could have said if I was an actual racist and thought like one. Some of the things I heard that could have been said is not fit to repeat. ”

The now alleged former Alto Properties Inc. Property Manager Stella Reddy has been told that what she said at the LTB hearing was considered “ mild ”?

WOW, so does this mean that someone explained to her that what she said was not appropriate, but it was okay as it only registered as “ mild ” on the list of offensive racist remarks?

The Applicants are very curious as to know who it was that explained to the now alleged former Alto Properties Inc. Property Manager Stella Reddy that her racially charged language was “ mild ” vs extreme.

Is this same mystery person a Racist Remarks Expert?

This “ mild ” statement made by the now alleged former Alto Properties Inc. Property Manager Stella Reddy is so bizarre that words cannot describe how ridiculous it really sounds.

It appears that the now alleged former Alto Properties Inc. Property Manager Stella Reddy is trying to negate her racially motivated behaviour at the LTB hearing by saying that it could have been a lot worse than it was.

So does the now alleged former Alto Properties Inc. Property Manager Stella Reddy think that she deserves some praise or some form of congratulations for resisting the urge to be even more racist than she already was?

That fact that the now alleged former Alto Properties Inc. Property Manager Stella Reddy thinks that because she did not go further than she did is some kind of special accomplishment, is beyond staggering.

It must have be the Applicants lucky day on September 26, 2017 that despite claiming not to be a racist, the now alleged former Alto Properties Inc. Property Manager Stella Reddy could have said things that would have been far more inappropriate and racist than her previous statements that were proclaimed by an unknown expert as “ mild ”.

So according to the now alleged former Alto Properties Inc. Property Manager Stella Reddy own words, implying that any “ mild ” racist comment does not make you a racist.

So what the now alleged former Alto Properties Inc. Property Manager Stella Reddy must be saying is. You’re a racist only when you…

  • use the “N” word to refer to a Black individual.
  • use a fire hose on a Black individuals to break up a peaceful protest,
  • force Black individuals to use different fountains, restaurants and washroom faculties.
  • make Black individuals sit in the balcony of a movie theatre.

And it does not atop there, the now alleged former Alto Properties Inc. Property Manager Stella Reddy goes on to state “ Some of the things I heard that could have been said is not fit to repeat. ”

Well once again it certainly must have been a good thing for the Applicant on that day that the now alleged former Alto Properties Inc. Property Manager Stella Reddy finally showed some restraint and decided not to use more profanity laced racist slurs that she heard, that she could have said, that were apparently not fit to be said in her email to the Applicants.

It is the Applicants position the now alleged former Alto Properties Inc. Property Manager Stella Reddy has not been living under a rock or in a cave her entire life. That despite their being a large population of whites in New Foundland vs. visible non – whites.

There is absolutely no way a 52 year old, born Canadian, white woman with a “ diverse ” family is “naive” that what she said and did in a public forum wasn’t offensive, inappropriate and racist.


( EXHIBIT # 107 )

( EXHIBIT # 108 ) page # 2

( EXHIBIT # 108 ) page # 1

The Applicants don’t buy into her claims of being “ Naive ” and neither can the HRTO. By accepting her laughable excuse, the HRTO would be just encouraging her behaviour as just as the Social Justice Tribunals Ontario Member Kevin Lundy did back on September 26, 2017 when he refused to correct her behaviour.

So why does the now alleged former Alto Properties Inc. Property Manager Stella Reddy think that society is okay with her racially charged language and prejudice actions and slurs?

Because when Social Justice Tribunals Ontario Member Kevin Lundy acknowledges her behaviour in his illegal eviction order and does nothing about it. It justify in the now alleged former Alto Properties Inc. Property Manager Stella Reddy own head that it is acceptable under certain circumstances.

Because an HRTO Arbitrator at the LTB did nothing about it, then it must be acceptable.

You see this problem was not created in the LTB by the Social Justice Tribunals Ontario Member Kevin Lundy. Nope not at all! He just enables it, like he did with the now alleged former Alto Properties Inc. Property Manager Stella Reddy.

This has been an ongoing problem for a very long time and it now looks like things are about to change with Social Justice Tribunals Ontario Members like Mary Truemner who this year finally drew a line in the sand that required witness not to step on or even over it.

It is clear and obvious that Social Justice Tribunals Ontario Members Mary Truemner has finally taken a position that many arbitrators would not over the years. She determined that there needs to be some form of decorum in legal proceedings and it appears that it is finally here that there is no reason or acceptance of racist behaviour in the HUMAN RIGHTS TRIBUAL OF ONTARIO.

With the above facts, the Applicants take the position that the now alleged former Alto Properties Inc. Property Manager Stella Reddy racially charged language and prejudice slurs and actions were not need and uncalled for in the LTB hearing, and in fact may have been said and done as a way to protect herself from any future litigation .

The now alleged former Alto Properties Inc. Property Manager Stella Reddy her racially charged language, prejudice slurs and her own racially motivated actions ARE NOT PROTECTED by absolute privilege as they were uttered not for the purposes of judicial proceedings as a witness.

12

APPROPERATLY DEALT WITH

It is pretty obvious after reviewing the document provided by the Applicants that the Social Justice Tribunals Ontario Member Kevin Lundy never considered any of the documents that the Applicants were duped into filing for their October 31, 2017 hearing on the September 26, 2017.

The Social Justice Tribunals Ontario Member Kevin Lundy basically conned the Applicants into giving the

3 Respondents a free preview/heads up into the Applicants case against them for October 31, 2018 on September 26, 2017.

It is pretty clear and obvious that the LTB and the Divisional Court have not and will not be dealing with the substance of the HRTO complaints against the 3 Respondents.

The substance of the LTB hearing was that of the 3 Respondents filed for eviction order for a Refusal of Entry.

The substance of the Divisional Court is the behaviour and bias of the Social Justice Tribunals Ontario Member Kevin Lundy.

The substance of the HRTO is to address the harassing, discriminating and acting in a reprisal manner by the now alleged former Alto Properties Inc. Property Manager Stella Reddy where she used her position with Alto Properties Inc. against the Applicants for calling her out.

The substance of the HRTO is to address the harassing, discriminating and acting in a reprisal manner by Alto Properties Inc. owner Luigi Liscio and Alto Properties Inc. owner Anthony where they used their position with Alto Properties Inc. against the Applicants to support their now alleged former Alto Properties Inc. Property Manager Stella Reddy and because they enforced their rights under the law.

It is the Applicants position that the now alleged former Alto Properties Inc. Property Manager Stella Reddy has deliberately made absolutely no arguments, quoted or presented any legal grounds in her written response to this issue.

It is the Applicants position that Alto Properties Inc. Property Manager Stella Reddy has chosen to forfeit her right to have any place at the table to argue any issues relating to appropriately dealt with, as she has deliberately not presented any documents or argument to collaborate and justify her request for a deferral and/or dismissal that she has requested.

It is the Applicants position that Alto Properties Inc. Property Manager Stella Reddy has taken it upon herself to not present the required documents to collaborate or justify her request for deferral and/or dismissal.

The now alleged former Alto Properties Inc. Property Manager Stella Reddy willfully and without any threats of reprisal, violence, repercussions or intimidation decided that she was not going to address the issue of deferral and/or dismissal that was requested by her in her response.

It appears that the now alleged former Alto Properties Inc. Property Manager Stella Reddy thinks that it is the HRTO responsibility and obligation to make her positions fully known, or to create an argument on her behalf and to present documents that help justify her own request for a deferral and/or dismissal.

It is Applicants position that this is not the case, and that the now alleged former Alto Properties Inc. Property Manager Stella Reddy should not have placed these inappropriate expectations upon HRTO, as it is solely HER responsibility to present, validate and defend her own request for deferral and/or dismissal.

It is the Applicants position that Alto Properties Inc. owner Luigi Liscio and Alto Properties Inc. owner Anthony Liscio have chosen to forfeit their right to have any place at the table to argue any issues relating to appropriately dealt with for a deferral and/or dismissal, as they have deliberately not provide a physical copy or digital copy of their authorities, present explanations about their authorities that are so vaguely explained or in some cases lack any type of explanation at all to justify their request for a deferral and/or dismissal that they had requested.

It is the Applicants position that Alto Properties Inc. owner Luigi Liscio and Alto Properties Inc. owner Anthony Liscio have taken it upon themselves to deliberately not present the required documents to collaborate or justify their request for deferral and/or dismissal.

Alto Properties Inc. owner Luigi Liscio and Alto Properties Inc. owner Anthony Liscio willfully and without any threats of reprisal, violence, repercussions or intimidation decided that they were not going to address some issue raised in their request for deferral and/or dismissal that was requested by them in their response.

It appears that Alto Properties Inc. owner Luigi Liscio and Alto Properties Inc. owner Anthony Liscio think that it is the HRTO responsibility and obligation to make their positions fully known, or to create an argument on their behalf and to present documents that help justify their own request for a deferral and/or dismissal.

It is Applicants position that this is not the case, and that Alto Properties Inc. owner Luigi Liscio and Alto Properties Inc. owner Anthony Liscio should not have placed these inappropriate expectations upon HRTO, as it is solely THEIR responsibility to present, validate and defend their own request for deferral and/or dismissal.

13

REPRISAL

It is the Applicants position that the now alleged former Alto Properties Inc. Property Manager Stella Reddy has deliberately made absolutely no arguments, quoted or presented any legal grounds in her written response to this issue.

It is the Applicants position that Alto Properties Inc. Property Manager Stella Reddy has chosen to forfeit her right to have any place at the table to argue any issues relating to appropriately dealt with, as she has deliberately not presented any documents or argument to collaborate and justify her request for a deferral and/or dismissal that she has requested.

It is the Applicants position that Alto Properties Inc. Property Manager Stella Reddy has taken it upon herself to not present the required documents to collaborate or justify her request for deferral and/or dismissal.

The now alleged former Alto Properties Inc. Property Manager Stella Reddy willfully and without any threats of reprisal, violence, repercussions or intimidation decided that she was not going to address the issue of deferral and/or dismissal that was requested by her in her response.

It appears that the now alleged former Alto Properties Inc. Property Manager Stella Reddy thinks that it is the HRTO responsibility and obligation to make her positions fully known, or to create an argument on her behalf and to present documents that help justify her own request for a deferral and/or dismissal.

It is Applicants position that this is not the case, and that the now alleged former Alto Properties Inc. Property Manager Stella Reddy should not have placed these inappropriate expectations upon HRTO, as it is solely HER responsibility to present, validate and defend her own request for deferral and/or dismissal.

It is clear that Alto Properties Inc. owner Luigi Liscio and Alto Properties Inc. owner Anthony Liscio had as much of a hand in the racially motivated discrimination and reprisal against the Applicants as their now alleged former Alto Properties Inc. Property Manager Stella Reddy did.

Alto Properties Inc. owner Luigi Liscio and Alto Properties Inc. owner Anthony Liscio state in their response “ It is respectfully submitted that none of the actions of the Respondents were either discriminatory, nor did they constitute reprisal. There is nothing in the record before the Tribunal to suggest that there was a threat made by the Respondents with the intent of punishing or retaliate against the Applicant for claiming or enforcing his rights under the code. It is respectfully submitted that to the extent that any correspondence does exist and was direct to the Applicant. It was intended, as set out on Ornelas to respond to the Applicant’s perceived attempts to ruin the personal Respondent’s reputation and that of his business.”

First let us address the obvious. Alto Properties Inc. owner Luigi Liscio and Alto Properties Inc. owner Anthony Liscio state “ There is nothing in the record before the Tribunal to suggest that there was a threat made by the Respondents with the intent of punishing or retaliate against the Applicant for claiming or enforcing his rights under the code. ”

That is correct there is nothing physical as in evidence, but what it also does not say is,

There is nothing in the record before the Tribunal to suggest that there was ANY ACTIONS made by the Respondents with the intent of punishing or retaliate against the Applicant for claiming or enforcing HIS OR HER rights under the code. Suggesting to the Applicants that there must be something in the record.

( EXHIBIT # 23 ) It is clear by reading the Applicants 107 pages of Statement of Facts that the 3 Respondents did not and would not have made the mistake of making any ought right threats to the Applicants by leaving any kind of paper trail.

Instead the 3 Respondents used illegal N5’s, which they knew were illegal and threats of eviction to try intimated the Applicants into compliance.

Their constant attempts to deliberate inconvenience and harassment the Applicants and their endless attempts to put finical and emotional stress upon the entire family.

Of course the 3 Respondents are smart enough to understand that implied ( read between the lines ) threats are far harder to prove then outright threats.

There is no argument that Alto Properties Inc. owner Luigi Liscio and Alto Properties Inc. owner Anthony Liscio are owners of the apartment complex 859 Kennedy Road where the Applicants live. There is no argument that the now alleged former Alto Properties Inc. Property Manager Stella Reddy was working for them in March 20018 as the Property Manager despite her many attempts to claims she was not.

It is the position of the Applicants that all the harassing, discriminating and acting in a reprisal manner by the now alleged former Alto Properties Inc. Proper Manager Stella Reddy against the Applicants had to be given the okay/thumbs up and embraced by Alto Properties Inc. owner Luigi Liscio and Alto Properties Inc. owner Anthony Liscio.

( EXHIBIT # 11, # 12 ) It was at the time Alto Properties Inc. owner Luigi Liscio and Alto Properties Inc. owner Anthony Liscio willfully and deliberately chose to ignore the Applicants concerns expressed in their letter(s) sent to them.

Alto Properties Inc. owner Luigi Liscio and Alto Properties Inc. owner Anthony Liscio stood by passively and encouraged and even participated alongside the now alleged former Alto Properties Inc. Property Manager Stella Reddy to inconvenience and harass the Applicants in retaliation for calling her out and her bosses out on their racist behaviour.

Alto Properties Inc. owner Luigi Liscio and Alto Properties Inc. owner Anthony Liscio are as guilty of the same behaviour the now alleged former Alto Properties Inc. Property Manager Stella Reddy as they stood by intentionally passive while giving the now alleged former Alto Properties Inc. Property Manager Stella Reddy the green light to do their bidding in retaliation for their letters.

This is a list of PAST BEHAVIOUR where it was actually brought to Alto Properties Inc. owner Luigi Liscio and Alto Properties Inc. owner Anthony Liscio attention about the now alleged former Alto Properties Inc. Property Manager Stella Reddy own racially motivated actions of harassment, discriminating and acting in a reprisal manner and/or where any sensible person would have concluded that there was some alterative motive behind her actions and/or behaviour.

PAST BEHAVIOUR #1 ( Please review Applicants Statement of Facts and documents for a more detailed explanation ) List of documents – 22, 23, 24, 25, 26, 27, 28, 29, 30, 31, 32

The Applicants forwarded a letter in regards to the newly installed video camera in the elevator on August 29, 2016.

Alto Properties Inc. owner Luigi Liscio, Alto Properties Inc. owner Anthony Liscio and now alleged former Alto Properties Inc. Property Manager Stella Reddy decided that instead of moving the video camera 6 inches to the left or place it on the east wall of the elevator.

The 3 Respondents left it where it was so it had direct sight into the Applicants unit when opening their door after exiting the elevator.

It has been proven that there was no requirement for the video camera to stay in that current position, that a better and wider “ direct view ” of the elevator door could have be obtained by simple moving it.

What was also proven is that by moving the video camera, the only “ direct view ” that would have been lost was that into the Applicants unit upon exiting the elevator.

It has also been proven by the newly installed surveillance system that was placed in the elevator is in the same area that was requested by the Applicant in August of 2017 as were denied by the 3 Respondents.

Alto Properties Inc. owner Luigi Liscio and Alto Properties Inc. owner Anthony okayed the new surveillance systems position, despite back in August 2017 claiming that the current view was the only view that had “ direct sight ” of the problem area.

So why did Alto Properties Inc. owner Luigi Liscio and Alto Properties Inc. owner Anthony Liscio and now alleged former Alto Properties Inc. Property Manager Stella Reddy refuse to move the video camera the first time when the Applicants asked?

Why didn’t Alto Properties Inc. owner Luigi Liscio not try and “ FIX ” this “ NONSENSE ”?

PAST BEHAVIOUR #2 ( Please review Applicants Statement of Facts and documents for a more detailed explanation ) List of documents – 38, 39, 40

1st illegal N5 ( August 31, 2016 ) – It was proven by the Social Justice Tribunals Ontario Member Kevin Lundy that this N5 given out by the 3 Respondents was given illegally as there was no 24 hour notice given and the Applicants had the right to refuse entry when Alto Properties Inc. owner Luigi Liscio, Alto Properties Inc. owner Anthony Liscio and/or the now alleged former Alto Properties Inc. Property Manager Stella Reddy appeared at their door requesting entry.

Again why did Alto Properties Inc. owner Luigi Liscio and Alto Properties Inc. owner Anthony Liscio encouraged the now alleged former Alto Properties Inc. Property Manager Stella Reddy to issue the Applicants this illegal N5?

It appears that Alto Properties Inc. owner Luigi Liscio and Alto Properties Inc. owner Anthony Liscio encouraged the now alleged former Alto Properties Inc. Property Manager Stella Reddy to pursue her own racially motivated actions of harassment, discriminating and acting in a reprisal manner in a joint effort.

Why didn’t Alto Properties Inc. owner Luigi Liscio not try and “ FIX ” this “ NONSENSE ”?

PAST BEHAVIOUR #3 ( Please review Applicants Statement of Facts and documents for a more detailed explanation ) List of documents – 41, 42, 43, 44, 45, 46, 47, 48, 49

The Applicants on August 31, 2016 outlined in an 8 page letter to Alto Properties Inc. owner Luigi Liscio and Alto Properties Inc. owner Anthony Liscio their previous concerns about the now alleged former Alto Properties Inc. Property Manager Stella Reddy.

If at the time Alto Properties Inc. owner Luigi Liscio and Alto Properties Inc. owner Anthony Liscio were so concerned in regards to the Applicants concerns. Alto Properties Inc. owner Luigi Liscio and Alto Properties Inc. owner Anthony Liscio could have freely asked the Applicants for more details and insight as to what was going on.

But they deliberately refused to!

Instead Alto Properties Inc. owner Luigi Liscio and Alto Properties Inc. owner Anthony Liscio decided that they only wanted to hear one side of the story and they relied solely upon the lies of the now alleged former Alto Properties Inc. Property Manager Stella Reddy who stated “ She has never been there.” as being the only actual facts about the situation.

Why were Alto Properties Inc. owner Luigi Liscio and Alto Properties Inc. owner Anthony Liscio not concerned about the racially charged language and prejudice slurs used by their now alleged former Alto Properties Inc. Property Manager Stella Reddy when brought up by the Applicants?

Was it because they took the same view as the now alleged former Alto Properties Inc. Property Manager Stella Reddy, that the Applicant was just some “ Black ” trying to use her complexion to get what she wanted?

Maybe it was that they finally found someone who had shared the same views as them?

Maybe they were afraid that they might be something to the Applicants concerns, and if true they would have to do something about it?

Why didn’t Alto Properties Inc. owner Luigi Liscio not try and “ FIX ” the situation?

PAST BEHAVIOUR #4 ( Please review Applicants Statement of Facts and documents for a more detailed explanation ) List of documents – 55, 57,58

The Applicants on October 17, 2016 outlined in a 2 page letter to Alto Properties Inc. owner Luigi Liscio and Alto Properties Inc. owner Anthony Liscio how again they were left sitting around all day by their now alleged former Alto Properties Inc. Property Manager Stella Reddy and were only notified of the cancelation by Ace Glass hours past the scheduled time.

Why didn’t Alto Properties Inc. owner Luigi Liscio not try and “ FIX ” this “ NONSENSE ”?

PAST BEHAVIOUR #5 ( Please review Applicants Statement of Facts and documents for a more detailed explanation ) List of documents – 56, 59, 60, 61, 62, 63, 64, 65, 66, 67, 68, 69, 70, 72, 73, 74

2nd illegal N5 ( October 18, 2016 ) – Alto Property Manager Stella Reddy again deliberately does not tell the Applicants that the 2nd scheduled appointment for Ace Glass the next day was again cancelled for the second day in a row.

Alto Properties Inc. owner Luigi Liscio and Alto Properties Inc. owner Anthony Liscio still green light the now alleged former Alto Properties Inc. Property Manager Stella Reddy to serve the Applicants with another 2nd illegal N5 for refusal of entry.

It was proven by the Social Justice Tribunals Ontario Member Kevin Lundy that this 2nd N5 given out by the 3 Respondents was given illegally as there was no 24 hour notice given and the Applicants had the right to refuse entry when Alto Properties Inc. owner Luigi Liscio, Alto Properties Inc. owner Anthony Liscio and/or the now alleged former Alto Properties Inc. Property Manager Stella Reddy appeared at their door requesting entry.

The 3 Respondents knew the appointment being cancelled by Ace Glass that same day and the Applicants were not given proper 24 hour notice.

In fact the now alleged former Alto Properties Inc. Property Manager Stella Reddy and all the time was having a conversation via emails with the Applicants when she received the cancellation by Ace Glass and still does not tell the Applicants.

Why didn’t Alto Properties Inc. owner Luigi Liscio not try and “ FIX ” this “ NONSENSE ”?

PAST BEHAVIOUR #6 ( Please review Applicants Statement of Facts and documents for a more detailed explanation ) List of documents – 71

The now alleged former Alto Properties Inc. Property Manager Stella Reddy forwards and email to Alto Properties Inc. owner Luigi Liscio and Alto Properties Inc. owner Anthony Liscio on October 19, 2016 stating “ They found the detector not working there, as the battery was missing. Was told by her partner that he removed it after battery was replaced in June as it was still beeping and said that they were told it would be replaced. Yet, in the letter she sent she didn’t say any of that, just that it was fine as the battery was already changed. No mention in her letter that it still beeped, that they removed the battery due to this beeping. Want me to have them charged under the Fire Code? ”

Why didn’t Alto Properties Inc. owner Luigi Liscio and Alto Properties Inc. owner Anthony Liscio not find her behaviour and request a little extreme and unusual?

How could they not determine that the now alleged former Alto Properties Inc. Property Manager Stella Reddy was unquestionably acting in retaliation manner against the Applicants for constantly call her out on her behaviour to her bosses?

There can be no argument that Alto Properties Inc. owner Luigi Liscio and Alto Properties Inc. owner Anthony Liscio were on notice about the now alleged former Alto Properties Inc. Property Manager Stella Reddy past harassing, discriminating and acting in a reprisal manner and use of racially charged language and statements direct at the Applicants.

At a bare minimum, they had to construe that the now alleged former Alto Properties Inc. Property Manager Stella Reddy was acting outside of a normal behaviour and in bad faith by deliberately trying to kick the proverbial Hornets’ Nest.

Alto Properties Inc. owner Luigi Liscio and Alto Properties Inc. owner Anthony Liscio had to understand that her behaviour and request were “ nonsense ” and an attempt to retaliate against the Applicants for calling her out to her bosses?

Why didn’t Alto Properties Inc. owner Luigi Liscio not try and “ FIX ” this “ NONSENSE ”?

The only explanation is that the 3 Respondents were jointly trying to provoke responses out of the Applicants, like the 2 illegal N5’s.

PAST BEHAVIOUR #7 ( Please review Applicants Statement of Facts and documents for a more detailed explanation ) List of documents – 87

It was not until the Applicants receive an email from the now alleged former Alto Properties Inc. Property Manager Stella Reddy herself on September 26, 2017 at the LTB hearing where she presented it to the Social Justice Tribunals Ontario Member Kevin Lundy as evidence against the Applicants for Refusal of Entry.

That the Applicants gained some valuable insight and it begin to clarify what has behind the now alleged former Alto Properties Inc. Property Manager Stella Reddy Obsessive Compulsive Behaviour or OCD to have the Applicants removed from the building.

After reading this email, Alto Properties Inc. owner Luigi Liscio and Alto Properties Inc. owner Anthony Liscio had to see and realize her Obsessive Compulsive behaviour or OCD and her immoral behaviour towards the Applicant was playing right out front of them.

The now alleged former Alto Properties Inc. Property Manager Stella Reddy in and email on August 24, 2017 stated “ Sorry Anthony, I can’t take this lying down anymore and I filed a personal complaint with the Human Rights against them for their behaviour. It is already gone as it was the first thing I did when I got home. They need to learn that just because she is black, they can’t throw out these accusations of racism and bigotry against people who don’t give them what they want or do things the way they want. This is their fall back to intimidate me to do things their way and I can’t do it anymore. The fact that they made all these accusations last year and nothing was done about it, they think they can keep it up and get away with it and it needs to stop. ”

It appears that after just over a year after the now alleged former Alto Properties Inc. Property Manager Stella Reddy started working for Alto Properties Inc. owner Luigi Liscio and Alto Properties Inc. owner Anthony Liscio. The truth has finally started to expose itself in this email between employers and their employee.

This email proves that the now alleged former Alto Properties Inc. Property Manager Stella Reddy had an axe to grind against the “ Black ” applicant and she wasn’t going to take this lying down anymore ”and get her pound of flesh.

The now alleged former Alto Properties Inc. Property Manager Stella Reddy stated “ they think they can keep it up and get away with it and it needs to stop.”

The question is, how did the now alleged former Alto Properties Inc. Property Manager Stella Reddy think she was going to make it stop?

The only real option she had was to try and use her position with Alto Properties Inc. to get them removed from the building. Which in turn now explains her Obsessive Compulsive behaviour or OCD in her attempts to build a case against the Applicants to have them removed from the building.

Alto Properties Inc. owner Luigi Liscio and Alto Properties Inc. owner Anthony Liscio want the HRTO to believe that they did not at a minimum concluded that their now alleged former Alto Properties Inc. Property Manager Stella Reddy was acting outside of a normal behaviour and not in bad faith?

Does Alto Properties Inc. owner Luigi Liscio and Alto Properties Inc. owner Anthony Liscio think that this type of harassment and racist motivated behaviour, racially charged language is normal and acceptable?

Knowing the history of her behaviour towards the Applicants before she even started and her subsequent harassing, discriminating and acting in a reprisal manner since they first met in June 2016?

PAST BEHAVIOUR #8 ( Please review Applicants Statement of Facts and documents for a more detailed explanation ) LTB Transcripts

Note: there are portions of the written transcripts that are labelled inaudible to the transcriber, but are clear in the recording where now alleged former Alto Properties Inc. Property Manager Stella Reddy says her prejudice slurs against New Foundlanders.

On September 26, 2017 at the LTB hearing filed by the 3 Respondents. The now alleged former Alto Properties Inc. Property Manager Stella Reddy uses racially charged language and prejudice slurs about New Foundlanders , the Applicant and her children, her very own nieces and nephews during the public hearing. The whole time being steadfast in her claims to not be a racist.

Her behaviour was so inappropriate that the Social Justice Tribunals Ontario Member Kevin Lundy made sure to make a reference about it in his illegal evection order.

Again, how could Alto Properties Inc. owner Luigi Liscio and Alto Properties Inc. owner Anthony Liscio not at a minimum concluded that their now alleged former Alto Properties Inc. Property Manager Stella Reddy was acting outside of a normal behaviour and in bad faith?

Again, why didn’t Alto Properties Inc. owner Luigi Liscio not try and “ FIX ” the situation even upon hearing his now alleged former Alto Properties Inc. Property Manager Stella Reddy speak so inappropriately in a public forum and knowing her history of racist motivated behaviour and bad faith towards the Applicants?

PAST BEHAVIOUR #9 ( Please review Applicants Statement of Facts and documents for a more detailed explanation ) List of documents – 120

On October 4, 2017 at 9:53 am, Alto Properties Inc. owner Luigi Liscio knocked on the Applicants unit door. The Applicants husband answered the door and invited Alto Properties Inc. owner Luigi Liscio and his fire inspector/contractor politely into the unit.

The fire inspector walked in, tested the smoke detector and then left. It took approximately 25 seconds.

Alto Properties Inc. owner Luigi Liscio remained in the doorway and the fire inspector/contractor left the unit and the Applicants husband turned and notice the now alleged former Alto Properties Inc. Property Manager Stella Reddy standing in the hallway in front of the elevator with a clipboard.

The Applicants husband figured the alleged former Alto Properties Inc. Property Manager Stella Reddy was now going to do her Annual Unit Inspection, but instead everyone walked away towards unit #304.

The Applicants husband than closed the door and continued to wait unit 5:00 for the Annual Unit Inspection to take place that was scheduled for that same day.

At 5:10, the Applicants sent an email to Alto Properties Inc. owner Anthony Liscio and the now alleged former Alto Properties Inc. Property Manager Stella Reddy after waiting over 8 hours for someone to do the Annual Unit Inspection stating “ It is now 5:10 pm and you have not returned to do the yearly inspection. You were here this morning to test the fire alarm with your contractor and made absolutely no mention that you would not be returning. I do not appreciate you having me sit here all day waiting for you AGAIN, and you could not be bothered to inform Allison or me that you were not going to return. According to your entry form you were supposed to do fire alarms and yearly inspections today between 9 am and 5 pm. You only completed the fire alarms. ”

On October 10, 2017 – 6 days later, the now alleged former Alto Properties Inc. Property Manager Stella Reddy finally responds at 11:49 am to the email that was sent back on October 4, 2017 by the Applicants.

The now alleged former Alto Properties Inc. Property Manager Stella Reddy stated “ Good Afternoon Mr. Read, Thank you for your email. Due to the hearing that was held on September 26, 2017, and we were waiting for the Hearing Order to come, it was prudent for staff not to attend the apartment to complete the annual inspection. Thank you for your time and if you have any questions please feel free to contact me. ”

So it appears that again it was not “ prudent ” at 9:53 am for Alto Properties Inc. owner Luigi Liscio and his now alleged former Alto Properties Inc. Property Manager Stella Reddy to inform the Applicants husband that they would not be returning to the Applicants unit to do the Annual Unit Inspection later that day while standing in the hallway.

So not only this time was it the now alleged former Alto Properties Inc. Property Manager Stella Reddy who left the Applicants husband sitting around 8 hours waiting for an appointment that was deliberately cancelled because it

wasn’t “ prudent ”and was deliberately again not notified for a 3rd time.

Now Alto Properties Inc. owner Luigi Liscio who was in on it also. It had to be Alto Properties Inc. owner Luigi Liscio and Alto Properties Inc. owner Anthony Liscio final call as to if the Annual Unit Inspection needed to be carried out or not.

It appears that now it was the 2 Respondents found it funny and enjoyed the idea of not notifying the Applicants of the cancelation of the Annual Unit Inspection and acting in bad faith.

It appears that now it was the 2 Respondents found it funny and enjoyed the idea of Applicants sitting around waiting for 8 hours for the Annual Unit Inspection and acting in bad faith.

It appears that now it was the 2 Respondents that found it funny and enjoyed the idea of inconveniencing the Applicants and acting in bad faith.

Again, did the 3 Respondents deliberately not tell the Applicants of the cancellation hoping to again provoke a response?

PAST BEHAVIOUR #10

On October 25, 2017 Alto Properties Inc. owner Luigi Liscio had a very friendly and polite conversation with the Applicants husband in the lobby of the building while Alto Properties Inc. owner Luigi Liscio was waiting for the now alleged former Alto Properties Inc. Property Manager Stella Reddy to come down the stairs as the elevator was out of service.

During their conversation, Alto Properties Inc. owner Luigi Liscio stated in his own words that the whole situation is

“nonsense” and that “ it could have got fixed ” and that “I never had a bad relationship with you guys.”

Alto Properties Inc. owner Luigi Liscio also went on to defend the now alleged former Alto Properties Inc. Property Manager Stella Reddy previous racially charged language in mid – June 2016 by stating that she told him “ She says, she’s never been there. ”

And yet Alto Properties Inc. owner Luigi Liscio and Alto Properties Inc. owner Anthony Liscio still allow the appeal in Divisional Court to continue to go forward, despite the case in the LTB hearing being in Alto Properties Inc. owner Luigi Liscio own words “ Nonsense ” “ could have been fixed ” and “ never had a bad relationship ” with the Applicants.

It has to make the HRTO wonder what was the real motivation behind Alto Properties Inc. owner Luigi Liscio and Alto Properties Inc. owner Anthony Liscio trying to get the Applicants evicted?

At the time of the LTB hearing, getting the eviction of October 03, 2017 in the mail and at the time of Applicants filing the appeal.

Alto Properties Inc. owner Luigi Liscio in his own words stated that it was all “ Nonsense ” “ could have been fixed ” and he “ never had a bad relationship ” with the Applicants, but still

he was okay with the idea of…
  • the Applicants having to move at the end of a cold October/beginning of November.
he was okay with the idea of…
  • the Applicants 2 children ( Grades 3 and 9 )having to transfer to new school.
he was okay with the idea of…
  • the Applicants 2 children having to start all over and try and make new friends in their new schools.
he was okay with the idea of…
  • the elevator not being in service and the Applicants having to travel up and down 3 narrow flights of stairs, carrying everything they own. ( boxes, furniture, beds ect. )
he was okay with the idea of…
  • the Applicants only having 3 weeks to find a place to move vs. a normal 2 months.
he was okay with the idea of…
  • the Applicant and/or her husband have to take time off work to go see places during business hours, losing money that would have helped pay for moving and everyday living.
he was okay with the idea of…
  • the Applicants having to move on the same day they were schedule to be heard at the LTB for their complaint against the 3 Respondents on October 31, 2017. for their harassment and racist motivated behaviour towards them.
he was okay with the idea of…
  • the whole situation turning the Applicants world upside down based on his own words “ Nonsense ” that

“ could have been fixed ” with the tenants that he has “ never had a bad relationship ” with.

So the HRTO has to wonder, why didn’t Alto Properties Inc. owner Luigi Liscio decide not to do the morally right thing and just call an end to all this “ Nonsense ”?

Alto Properties Inc. owner Luigi Liscio stated that the whole situation was “ Nonsense ” that it

“ could have been fixed ” and that he has “ never had a bad relationship ” with the Applicants.

And still he chose to ignore all of his own words and feelings about the situation so they continue to fight to have the Applicants evicted from his building?

It appears to the Applicants that there was something much larger holding Alto Properties Inc. owner Luigi Liscio back from doing what was morally right?

You see Alto Properties Inc. owner Luigi Liscio also stated in his comments on October 25, 2017 to the Applicants husband that he was also upset that they had went to the Divisional Court and it “ affected ” him and “ you hit my business ” and they “ should know better ”

There is no debate that he even at times becomes a willing participant alongside his now alleged former Alto Properties Inc. Property Manager Stella Reddy, encouraging and enabling her behaviour.

It appears that another new motivation is that of resentment because the Applicants again have enforced their rights under the law to file an appeal with Divisional Court.

It appears to the Applicants that Alto Properties Inc. owner Luigi Liscio is irritated that all these legal proceedings are still ongoing and costing him and his business money.

The HRTO has to wonder why a property owner who has “ never had a bad relationship ” with a tenants, would be so willing to spend more money to fight so hard to have them evicted, knowing it will “ affected ” him and hit his

“ business ” over “ nonsense ”?

So along with Alto Properties Inc. owner Luigi Liscio and Alto Properties Inc. owner Anthony Liscio intentional lack of interest and motivation to correct their now alleged former Alto Properties Inc. Property Manager Stella Reddy harassing, discriminating and acting in a reprisal manner towards the Applicant, in her quest to get them removed from the building.

It appears that Alto Properties Inc. owner Luigi Liscio now is now also retaliating against the Applicants because they enforced their rights to appeal to Divisional Court and they “ should known better ”

Despite the fact that Alto Properties Inc. owner Luigi Liscio saying after the LTB hearing on September 26, 2017 to the Applicants husband he “ never had a bad relationship “ with them.

( EXHIBIT # 109 ) Alto Properties Inc. owner Luigi Liscio and Alto Properties Inc. owner Anthony Liscio again sat on their hands and allowed their alleged former Alto Properties Inc. Property Manager Stella Reddy to mislead the Social Justice Tribunals Ontario Member Kevin Lundy into believing that “ The tenancy, which commenced in June, 2015 has been plagued by both hostility and profound lack of cooperation ”

( EXHIBIT # 49 ) And because Alto Properties Inc. owner Luigi Liscio and Alto Properties Inc. owner Anthony Liscio allowed her to obviously mislead the LTB and their lack of actions, condoning her. It then opened the door for the alleged former Alto Properties Inc. Property Manager Stella Reddy to later make such statements like the relationship between the Applicants and the owners is so “ broken ” that even if the Divisional Court was to rule in their favor.

There is no way they could stay in the building because “ It is just not done. ”

So now both these lies have been discredited by Alto Properties Inc. owner Luigi Liscio who admitted that he “ never had a bad relationship ” with the Applicants.

It again appears that some of the answers to the Applicants questions of

  1. Why was Alto Properties Inc. owner Luigi Liscio and Alto Properties Inc. owner Anthony Liscio encouraging her?
  2. Why didn’t Alto Properties Inc. owner Luigi Liscio not try and “ FIX ” this? are becoming clear.

There can be no doubt that Alto Properties Inc. owner Luigi Liscio and Alto Properties Inc. owner Anthony Liscio were in on it and knew what was going on!

It is the Applicants position that as the owners, they are responsible for what goes on in their building with their tenants and staff.

To think that 2 grown adults did not recognize what their alleged former Alto Properties Inc. Property Manager Stella Reddy was doing, would equate to them being some form of simpleton that lacked any common sense.

Which is pretty obvious and inaccurate as they are more than capable of maintain their multiple properties in and around the Toronto area.

Let us quickly touch on the previous Property Managers Angie and Chris, who worked for Alto Properties Inc. owner Luigi Liscio and Alto Properties Inc. owner Anthony Liscio.

These are the same Property Managers who threatened and tried to intimidate the Applicants back September 2015 into allow entry into their unit also without proper notice.

According to Alto Properties Inc. owner Luigi Liscio they were fired because they were “ Bad News ”. The Applicants have to wonder what does Alto Properties Inc. owner Luigi Liscio mean by “ Bad News ”? Were they fired because they threatened and tried to intimidate one too many tenants?

Were they fired because they tried to entry a tenants unit without giving proper notice?

Was the now alleged former Alto Properties Inc. Property Manager Stella Reddy also fired because she lied one to many times or tried to entry into a tenants unit without giving proper notice?

It was proven by the Social Justice Tribunals Ontario Member Kevin Lundy that the illegal N5’s given before and after September 26, 2017 to the Applicants by the now alleged former Alto Properties Inc. Property Manager Stella Reddy were basically illegal and would have no standing in a Tribunal hearing.


( EXHIBIT # 97 )

( EXHIBIT # 110 )

Despite giving the Applicant numerous illegal N5’s, the now alleged former Alto Properties Inc. Property Manager Stella Reddy insist that she is “ rule driven person ” and swears she is a “ professional ” when dealing with tenants.

She has went on to stated that she “ actually quotes the regulations, copy and paste directly from the written rules ”

as that she “ prefer the rules and regulations of property management to speak ” for her.

So being that the now alleged former Alto Properties Inc. Property Manager Stella Reddy admits that she was so informed on the rules and regulations, it only confirms that she willingly knew the N5’s were illegal when creating them, and still she issued them to the Applicant knowing that they did not fall within the rules and regulations set out in the Residential Tenancies Act.

Which means that the only reason the now alleged former Alto Properties Inc. Property Manager Stella Reddy issue these illegal N5’s was to intimidate and to retaliate against the Applicants for enforcing their rights under the

Residential Tenancies Act and/or calling for her out on her continuous harassing, discriminating and acting in a reprisal manner to her bosses Alto Properties Inc. owner Luigi Liscio and Alto Properties Inc. owner Anthony Liscio.

( EXHIBIT # 103 ) It appears that and the now alleged former Alto Properties Inc. Property Manager Stella Reddy thought in her email on August 24, 2017 to Alto Properties Inc. owner Luigi Liscio and Alto Properties Inc. owner Anthony Liscio resented that fact the this Applicant was “ Black ” and she even went so far as to convince herself by playing the race card against her.

the now alleged former Alto Properties Inc. Property Manager Stella Reddy did this to help her justify to herself, her own actions of harassing, discriminating and acting in a reprisal manner since she started towards the Applicants.

This letter date August 24, 2017 is not the only time that the now alleged former Alto Properties Inc. Property Manager Stella Reddy as referred to the Applicant as that “ Black ”.

( EXHIBIT # 111 ) On this same day, the now alleged former Alto Properties Inc. Property Manager Stella Reddy continued on with her racist rants in an HRTO complaint she filed.

( EXHIBIT # 112 ) page #9 The now alleged former Alto Properties Inc. Property Manager Stella Reddy stated on page # 9 of her HRTO complaint against the Applicants brother Darwin Charles “ Due to the fact that Ms. Read is Black, they are using the fact that I am not as a way to bully me and by making accusations against me as being a racist as a way to intimidate me. ”

( EXHIBIT # 112 ) page # 18  The now alleged former Alto Properties Inc. Property Manager Stella Reddy stated on page # 18 of her HRTO complaint against the Applicants brother Darwin Charles “ I am tying to do my job as building staff and when they don’t agree with how I do my job, nor the regulations I have to follow they say I am racist and a bigot and out to get them because she is black. ”

So it appears that 3 times in the same day, the now alleged former Alto Properties Inc. Property Manager Stella Reddy played the race card claiming that the “ Black ” Applicant is black and is trying to use her “ Black ” completion to

“ Bully ” and “ intimidate ” her.

The now alleged former Alto Properties Inc. Property Manager Stella Reddy also states that the “ Black ” Applicant is

“ using the fact that I am ” white.

So not only does the now alleged former Alto Properties Inc. Property Manager Stella Reddy played the race card claiming that the “ Black ” Applicant is black and is trying to use her “ Black ” complexion to “ Bully ” and

“ intimidate ” her. She also says that the “ Black ” Applicant is only doing it because she is white.

Let it be noted that the Applicants HAVE NEVER referred to the now alleged former Alto Properties Inc. Property Manager Stella Reddy whiteness as being any source of her harassing, discriminating and acting in a reprisal manner against them.

It is clear by this point that Alto Properties Inc. owner Luigi Liscio and Alto Properties Inc. owner Anthony Liscio could not give any less of a concern in regards to the harassing, discriminating and acting in a reprisal manner of their beloved now alleged former Alto Properties Inc. Property Manager Stella Reddy.

It appears that this is type racist behaviour is a requirement when applying for the position of Property Manager at 859 Kennedy Road. You must be willing to try and intimidate tenants with eviction if they stand up for their rights under the law to a proper 24 hour Notice of Entry.

By this point a normal person would hear all the bells and whistles going off in their head. Alto Properties Inc. owner Luigi Liscio and Alto Properties Inc. owner Anthony Liscio had to of known that all the N5’s were illegal as the Applicants pointed it out for them in their letters addressed to them.

But yet again they were okay with the idea of them just sitting on their hands during all this “ Nonsense ” that “ could have been fixed ” but in the end, it appears that their personal beliefs against the Applicants out weighted what was morally right and in good faith.

PAST BEHAVIOUR #10 ( Please review Applicants Statement of Facts and documents for a more detailed explanation ) List of documents – 136, 137, 138, 139, 140, 141, 142, 143

EXHIBIT # 113, #114, #115, #116, # 117, 118, # 119, #120

Email date September 09, 2018 to the HRTO – Yari Zabikhulla <Zabikhulla.Yari@ontario.ca>

On March 14, 2018 the Applicants asked for a parking space at the building for their new 2018 car. They were met with an email by the now alleged former Alto Properties Inc. Property Manager Stella Reddy where she stated “ Dear Ms. Read, We hope this letter finds you and your family well. We are writing to you in response to the text message received today with the request for a parking spot on the property. First, thank you your request but please note text message is not an acceptable track able way of communication between tenants and building staff, as per the RentSafeTO Bylaw, as texts are not easily printable for tenant files and for review by City Officials upon their request. Please submit all requests in writing by either our Tenant Request Form or by email in the future. At this time we do not have any parking spaces available on the property and if you wish to be added to the waiting list for a parking spot please submit the vehicle information with your name and apartment number and we will advise you when we have something available for you to rent. Due to the limited parking spaces available in Visitors Parking area we can’t allow tenant to temporarily park there as we do not have enough spaces for all whom are waiting. I am sorry but you will have to find a parking space off site as some others have had to do. ”

This statement made by the now alleged former Alto Properties Inc. Property Manager Stella Reddy was proven to be untrue as the new all white unit #306 was given a building parking space # 029, and they were also allowed to park their 2nd car in visitor parking with a pass given to them by the now alleged former Alto Properties Inc. Property Manager Stella Reddy.

All the time the Applicants being told to park their ONLY car off site due to the parking rules that the now alleged former Alto Properties Inc. Property Manager Stella Reddy was now breaking for the all-white #306.

It needs to be noted that the 2 units referred as parking off site by the now alleged former Alto Properties Inc. Property Manager Stella Reddy were units #302 and #305

Unit # 302 – had been parking offsite for over a year and they too were an interracial couple like the Applicants. White male and Black female with 1 bi-racial child.

They too also lived her years and where on the “ waiting list ” long before the new all-white unit #306 moved in.

The other unit #305 – who also was here before the all-white unit #306 and parking offsite for about 6 months. What was unfortunately for them was they had a lot on non–white friends visiting on weekends and they too were on the alleged “ waiting list ” long before the all-white unit #306 moved in.

Despite these two unit being a waiting list for a long period of time, the now alleged former Alto Properties Inc. Property Manager Stella Reddy allowed the all-white unit # 306 to jump from the bottom of the “ waiting list ” to getting a 2nd parking spot for their vehicle over units # 302 and #305.

So back to when the after the Applicants received the email about no parking. It appears that the 3 Respondents enjoyed the idea trying to inconvenience and harass the Applicant by forcing them to park their only car off site, subsequently having to pay someone or some place to park every day as Scarborough does not allow for overnight parking on the streets.

It appears that now Alto Properties Inc. owner Luigi Liscio figures since the Applicant enforced their rights to file in Divisional Court and it “ affected ” him and “ you hit my business ” he was now going to return the favour by retaliating against them with parking.

The Applicants had to try and find parking someplace overnight, knowing that they were not going to find a place for free. It was pretty obvious like units # 302 and # 305, they too would have to pay someone to use their driveway to park in every night to avoid getting tickets.

This now begins to explain why Alto Properties Inc. owner Luigi Liscio did nothing about the “ nonsense ” and why he certainly had no desire to try and “ FIX ” the situation.

You see the applicants are entitles to 1 free parking space according to their lease. It appears that the 3 Respondents wanted to make their money charging new tenants for parking verses giving the Applicants their free space.

PAST BEHAVIOUR #11 ( Please review Applicants Statement of Facts and documents for a more detailed explanation ) List of documents – 144, 145, 146, 147, 148

On June 3, 2018 the 3 Respondents figured that this would be a great opportunity to try and kick the Applicants while they were down by acting in bad faith.

The 3 Respondents after 8 months decided that now they wanted to request the last month’s deposit that was used in October 2017 while waiting for finding from the LTB hearing.

It is amazing how on the 3 Respondents on June 2, 2018 noticed that the Applicants rent was short by $146.88 and they instantly thought and cheered among themselves thinking that Applicants were suddenly hurting financially and could not pay the rent in full.

What they did not realize is that the Applicant had not yet forwarded them the receipt for the counter top toaster oven they purchased when sending out the e – transfer for the rent.

The 3 Respondents now thought they could seize the opportunity to try and build another case to have the Applicants removed from the building by not being able to paying their rent in full or give back the deposit.

What is absolutely amazing about what transpired over these 3 days, is how bad minded and spiteful the 3 Respondents are in their quest to have the Applicants removed from the building.

It appears they thought it was just another opportunity for them to try and retaliate against the Applicants for all the perceived hassle they figured they have put them through well the Applicants enforced their rights.

It appears that now as Alto Properties Inc. owner Luigi Liscio comments about him being upset that they had went to the Divisional Court and it “ affected ” him and “ you hit my business ” is a continuous motivation for reprisal against the Applicants.

This would explain why Alto Properties Inc. owner Luigi Liscio was willing to do nothing about the “ nonsense ” that was playing out, and why he certainly had no desire to try and “ FIX ” the situation.

PAST BEHAVIOUR #12

( EXHIBIT # 121 ) On July 4, 2018 the Applicants forwarded an email to Alto Properties Inc. owner Luigi Liscio, Alto Properties Inc. owner Anthony Liscio in regards to their now alleged former Alto Properties Inc. Property Manager Stella Reddy Obsessive Compulsive Behaviour or OCD.

The Applicants attached a series of emails by the now alleged former Alto Properties Inc. Property Manager Stella Reddy to the Applicants where she goes off on long rants trying to plead her case.

She goes on to try and convince the Applicants that they are wrong and that if they continue they will be exposed as liars. And that everything that has transpired between her and the Applicants was strictly brought upon by them and not by her harassing, discriminating and acting in a reprisal manner against them.

After receiving this email, Alto Properties Inc. owner Luigi Liscio, Alto Properties Inc. owner Anthony Liscio again did nothing but sit on their hands.

Again, how could Alto Properties Inc. owner Luigi Liscio and Alto Properties Inc. owner Anthony Liscio not at a minimum concluded that their now alleged former Alto Properties Inc. Property Manager Stella Reddy was acting outside of a normal behaviour and in bad faith?

Again, why didn’t Alto Properties Inc. owner Luigi Liscio not try and “ FIX ” the situation?

Even upon seeing these emails from their now alleged former Alto Properties Inc. Property Manager Stella Reddy, it appears that Alto Properties Inc. owner Luigi Liscio and Alto Properties Inc. owner Anthony still thought it was normal behaviour for her, knowing her history of racist behaviour and bad faith towards the Applicants.

Instead, now alleged former Alto Properties Inc. Property Manager Stella Reddy decided that she was not doing it anymore and she alleged quit!

It appears that it was now alleged former Alto Properties Inc. Property Manager Stella Reddy that fixed the situation and not Alto Properties Inc. owner Luigi Liscio, Alto Properties Inc. owner Anthony Liscio by quitting and not getting fired for her behaviour.

The question the Applicants and the HRTO need to know is how long did Alto Properties Inc. owner Luigi Liscio, Alto Properties Inc. owner Anthony Liscio intend to allow the now alleged former Alto Properties Inc. Property Manager Stella Reddy to have free range to do whatever she wanted against the Applicants before they eventually HAD TO INTERVENE?

PAST BEHAVIOUR #13

( EXHIBIT # 122 ) It has been 461 days since the LTB hearing and 486 days since the City of Toronto gave the 3 Respondents the Order to make the required repairs in the Applicants unit.

Despite their false claims of trying to make the repairs since the subsequently order. They have in fact still done nothing and made not attempts to “ FIX ” the outstanding issues since 2015.

The now alleged former Alto Properties Inc. Property Manager Stella Reddy has been quoted as saying the city immediately withdrew their Order upon hearing about the LTB hearing and the potential eviction.

This is a factual lie. Upon the Applicants speaking with the city, they were notified that the now alleged former Alto Properties Inc. Property Manager Stella Reddy was asked sometime in March of 2018 if they had complied with the work order sent back in September 2017.

So it appears that once again the now alleged former Alto Properties Inc. Property Manager Stella Reddy has grossly and deliberately lied to the HRTO in hopes of making the Applicants look bad.

The Applicants would like to point out that 6 different people have been in and out of the Applicants unit over 20 times for the reasons on the City Order and still to this day the problems go on.

It appears that the 3 Respondents think that it is the Applicants job to chase them to get work done. The Applicants were more than cooperative in the beginning when everyone was showing up unannounced and wanted to view the issues over and over and over.

But at some point the Applicants got tired of the rotary door approach to the fixing the problems that the 3 Respondents have taken.

The now alleged former Alto Properties Inc. Property Manager Stella Reddy states that she has tried to work with tenants, but not once can she show anytime, where she has made any attempts to work with the Applicants schedule.

The now alleged former Alto Properties Inc. Property Manager Stella Reddy approach to the Applicants has always been her way or the highway!

Let us not forget about 3 times the 3 Respondents left the Applicants sitting in their unit waiting for someone to show up, who never did and they were not notified of the cancelation.

The Applicants have shown how the now alleged former Alto Properties Inc. Property Manager Stella Reddy has gone out of her way to accommodate the all-white unit # 306 for parking.

It can also been shown how the now alleged former Alto Properties Inc. Property Manager Stella Reddy has also gone out of her way to accommodate another all-white unit in regards to repairs in their unit.

( EXHIBIT # 123 ) The all-white unit #402 were given a Notice of Entry for June 07, 2017 to have their balcony door handle fixed by the now alleged former Alto Properties Inc. Property Manager Stella Reddy after putting in a Maintenance Request Form.

( EXHIBIT # 124 ) Unit #402 email the now alleged former Alto Properties Inc. Property Manager Stella Reddy on June 06, 2017 and stated “ Hi Stella and Russel, You would like to inspect our balcony door tomorrow from 1pm to 5pm. I would like to be there as well. My shift doesn’t end until 7:30pm, but I will try to leave work earlier so we can meet some wear in the middle. I will tell you not that it is missing just 1 screw for the face plate if you wanted to be prepared and have that on hand we can complete this inspection to 100% complete. Thank you and look forward to hearing from you soon. ”

( EXHIBIT # 125 ) The now alleged former Alto Properties Inc. Property Manager Stella Reddy emailed back on June 07, 2017 and stated “ Good morning Kirk, We have no issue with you being home while we are there. Please let us

know when you are at home and we will attend your apartment. Regards Stella Reddy ”

So it appears that the interracial house hold of the Applicants is not, nor have they ever been afforded the privilege of being able to work cooperatively by the now alleged former Alto Properties Inc. Property Manager Stella Reddy like the all-white unit #402.

So now the Applicants have 2 scenarios where all-white units were given a privilege and they were not.

It appears to the Applicants that there still WHITE PRIVALGE alive and well at 859 Kennedy Road. The only questions the Applicants have are,

Does the now alleged former Alto Properties Inc. Property Manager Stella Reddy not like

  • the fact that the Applicants are in an interracial marriage?
  • they have the 2 bi-racial children together?
  • they are married and living together verses the mother being single and rasing the kids on her own?
  • that the father is appears to be Canadian and the mother is appears to be born abroad?
  • the idea of their 2 “ Mullato ” children being born in Canada?

There is absolutely no way to know, unless the now alleged former Alto Properties Inc. Property Manager Stella Reddy decides to tell the HRTO. But it is definitely pretty obviously clear that if you are an all-white unit at 859 Kennedy Road, you have a far better chance of not receiving her harassing, discriminating and acting in a reprisal manner used against you.

The now alleged former Alto Properties Inc. Property Manager Stella Reddy can NOT show HRTO at any time where she made any attempt to try accommodate the interracial house hold of the Applicants even when they requested it themselves.

It appears that all-white units in 859 Kennedy Road get this privilege of being accommodated, whereas interracial units like the Applicants, #302 and #305 do not.

In regards to Alto Properties Inc. owner Luigi Liscio, Alto Properties Inc. owner Anthony Liscio. It appears to the Applicants that they are just hoping the Applicants get tired of living with a bathroom that is falling apart and will move out, ending there legal problems in Divisional Court.

It appears that Alto Properties Inc. owner Luigi Liscio and Alto Properties Inc. owner Anthony Liscio are not willing to spend money to “ FIX ”anything inside the Applicants unit. But they are willing to continue to fight to remove Tenants they “ never had a bad relationship ” over “ nonsense ” that “ could have been fixed ”.

It appears that since the Applicants appeal has affected Alto Properties Inc. owner Luigi Liscio bottom line through his business. He/they will now cause inconvenience for the Applicants by not getting their bathroom, stove and windows fixed after 3 years because they “ should known better! ”

PAST BEHAVIOUR #14

So the Applicants 2 bedroom unit has gone up in rent value since January from $1400 to now $1750 in August. That is a 25% rent increase between January 2018 to August 2018.

As yes, Alto Properties Inc. owner Luigi Liscio and Alto Properties Inc. owner Anthony Liscio can charge whatever they want to new tenants moving for rent, but they are not able to use this as one of their forms of motivation to have them removed from the building.

You see the Applicants pay $1106.64 monthly for their 2 bedroom unit, unlike the unit directly beside them unit #302 who now $1750.

Now if the Applicants were to be evicted or leave, Alto Properties Inc. owner Luigi Liscio and Alto Properties Inc. owner Anthony could raise the rent for the unit by 63%. That means an increase profit of $1750 a month and $7,728 a year.

It is pretty obvious that Alto Properties Inc. owner Luigi Liscio and Alto Properties Inc. owner Anthony Liscio were never concerned about the “ Nonsense ” that “ could have been fixed ” for the tenants they “ never had a bad relationship ” with.

But it appears to the Applicants through Alto Properties Inc. owner Luigi Liscio and Alto Properties Inc. owner Anthony Liscio actions that greed and profits reigns supreme over morally what’s right.

It is pretty obvious from when the alleged former Alto Properties Inc. Property Manager Stella Reddy started using her racially charged language, prejudice slurs and her own racially motivated actions of harassment, discriminating and acting in a reprisal manner against the Applicants.

Alto Properties Inc. owner Luigi Liscio and Alto Properties Inc. owner Anthony Liscio have done but sat on their hands and let their the alleged former Alto Properties Inc. Property Manager Stella Reddy have free ranger of the building and subsequently been throwing money hand over fist at the situation to have the applicants removed from the building despite the whole situation being “ Nonsense ” that “ could have been fixed ” for the tenants they “ never had a bad relationship ” with.

It also appears that now Alto Properties Inc. owner Luigi Liscio and Alto Properties Inc. owner Anthony Liscio have not only a racial motivations as proven by the Applicants throughout this reply. But they now appear to also have finical motivations.

So upon reviewing the unprecedented powers given to their now alleged former Alto Properties Inc. Property Manager Stella Reddy to go right ahead to harassing, threaten, intimidate, inconvenience, retaliate and provoke the Applicants in their combined effort to build a case on them to get them out for calling them all out on their behaviour.

The fact that Alto Properties Inc. owner Luigi Liscio and Alto Properties Inc. owner Anthony Liscio have made absolutely reference or defence to any of the allegations against them or their now alleged former Alto Properties Inc. Property Manager Stella Reddy.

They have chosen to stay utterly silence on the issues and have offered the HRTO nothing to consider in regards to their behaviour.

Their only thing that one might be able to be considered as a defence is their there opening line in their response

“ It is respectfully submitted that none of the actions of the Respondents were either discriminatory, nor did they constitute reprisal. ”

It is pretty obvious that the Applicants where the racially target by now alleged former Alto Properties Inc. Property Manager Stella Reddy for retaliating based on the family dynamics.

The HRTO cannot even say that she just didn’t like the Applicants, because she has strategically has taken every opportunity to refer to the Applicants complexion, and even accusing the Applicant of acting out towards her because she is white.

The only questions the HRTO has to figure out is what was it about the Applicants family the now alleged former Alto Properties Inc. Property Manager Stella Reddy didn’t like?

  1. We know by the now alleged former Alto Properties Inc. Property Manager Stella Reddy own words ( twice ) used the word “ Mulatto ” and not bi – racial and that it is an acceptable term to use in public and in a public form when referring to the Applicants children in their presence.
  • We know by the now alleged former Alto Properties Inc. Property Manager Stella Reddy own words that she thinks that light complexion individuals are more “ beautiful ” than individuals with a dark complexion. As she referenced this about the Applicants children and her own nephew, who she deliberately lied about in the LTB as a defence as to show why she can’t be a racist and to down play her favoritism for light complexion individuals.
  • We know by the now alleged former Alto Properties Inc. Property Manager Stella Reddy own words in a public forum, that she is comfortable in refereeing to her own nieces and nephews  “ AS BLACK AS YOU CAN GET ” as a lie and as a defence as to show why she can’t be a racist.
  • We know by the now alleged former Alto Properties Inc. Property Manager Stella Reddy own words and actions in a public forum, pointing at the Applicant . She stated that here nephew was “ HE’S EVEN DARKER THAN SHE ” as a defence as to why she can’t be a racist. Later being proven as a liar through her own family photographs that he was not.
  • We know by the now alleged former Alto Properties Inc. Property Manager Stella Reddy own words she thinks that “ no one will give a shit what I said ” in the LTB hearing because she thinks that her lie is a “ normal reaction ”.
  • We know by the now alleged former Alto Properties Inc. Property Manager Stella Reddy own words she refers to the Applicant a some “ Black ” who she thinks is “ throw out these accusations of racism and bigotry ” in an attempt “ to intimidate ” her “ to do things their way ”.
  • We know by the now alleged former Alto Properties Inc. Property Manager Stella Reddy own words stated that the “ Black ” Applicant was racist towards her she uttered “ Ms. Read is Black, they are using the fact that I am not ”
  • We know by the now alleged former Alto Properties Inc. Property Manager Stella Reddy thinks it is okay to deliberately lie to the HRTO on numerous occasions when trying to make a point a deceptive point.
  • We know by the now alleged former Alto Properties Inc. Property Manager Stella Reddy own words that she thinks it is okay to ask non–whites “ Where are you from? ” based on their complexion, assuming they cannot be born in Canada.
  1. We know by the now alleged former Alto Properties Inc. Property Manager Stella Reddy own words she thinks it is okay to say things like “ I am very familiar with the Ontario Residential Tenancies Act because I have been a superintendent for 16 years here in Canada ” to non–whites as if their previous work or educational experience does not equal to that of hers because it was not in Canada.

The Applicants and the HRTO may never know the real reason behind the now alleged former Alto Properties Inc. Property Manager Stella Reddy racially charged language, prejudice slurs and her own racially motivated actions of harassment, discriminating and acting in a reprisal manner, but we all do know in her own words she stated;

1.       “ just because she is black, ”

  • “ because she is black, ”

3.       “I called her children mullato, ”

  • “ I did say that my nephew in law was as black as black, ”

5.       “ I have very beautiful great nephews and nieces who are half black, ”

  • “ my nephew is as black as you can get, ”

7.       “ He’s even darker than she, ”

  • Due to the fact that Ms. Read is BLACK. ”

( EXHIBIT # 126 ) And still the now alleged former Alto Properties Inc. Property Manager Stella Reddy will still demand and claim that I see people as people. To me it don’t matter what they look like, ”

It appears that the now alleged former Alto Properties Inc. Property Manager Stella Reddy has a very extraordinary way of not seeing people without seeing the complexion of their “ Black ” skin!

It appears that once again the now alleged former Alto Properties Inc. Property Manager Stella Reddy has tried to represent herself as being something that he is clearly not to the HRTO again.

14

ABUSE OF PROCESS

It is the Applicants position that Alto Properties Inc. Property Manager Stella Reddy has chosen to forfeit her right to have any place at the table to argue any issues relating to her own request for a deferral and/or dismissal, as she has deliberately not presented any documents or argument to collaborate and justify her request for a deferral and/or dismissal that she has requested.

It is the Applicants position that Alto Properties Inc. Property Manager Stella Reddy has taken it upon herself to not present the required documents to collaborate or justify her request for deferral and/or dismissal.

The now alleged former Alto Properties Inc. Property Manager Stella Reddy willfully and without any threats of reprisal, violence, repercussions or intimidation decided that she was not going to address the issue of deferral and/or dismissal that was requested by her in her response.

It appears that the now alleged former Alto Properties Inc. Property Manager Stella Reddy thinks that it is the HRTO responsibility and obligation to make her positions fully known, or to create an argument on her behalf and to present documents that help justify her own request for a deferral and/or dismissal.

It is Applicants position that this is not the case, and that the now alleged former Alto Properties Inc. Property Manager Stella Reddy should not have placed these inappropriate expectations upon HRTO, as it is solely HER responsibility to present, validate and defend her own request for deferral and/or dismissal.

( EXHIBIT # 127 ) The Ministry of the Attorney General of Ontario defines “abuse of process” with respect to a proceeding, as:

·         a claim or pleading that is clearly unfounded in fact or in law;

  • conduct that is frivolous, vexatious or intended to delay;

·         a claim made, or a proceeding brought or conducted, in bad faith;

  • the use of procedure that is excessive or unreasonable or that causes undue prejudice to another person or attempts to defeat the ends of justice; and

·         an attempt to restrict public participation by any person;

It is once again the Applicants position that Alto Properties Inc. Property Manager Stella Reddy has chosen to forfeit her right to have any place at the table to argue any issues relating to her own request for a deferral and/or dismissal, as she has not presented any material or argument to collaborate and justify her request for a deferral and/or dismissal that she requested.

It is the Applicants position that Alto Properties Inc. Property Manager Stella Reddy has taken it upon herself to not present a required documents to collaborate or justify her request for deferral and/or dismissal.

The now alleged former Alto Properties Inc. Property Manager Stella Reddy willfully and without any threats of reprisal, violence, repercussions or intimidation decided that she was not going to address the issue of deferral and/or dismissal that was requested by her in her response.

It appears that the now alleged former Alto Properties Inc. Property Manager Stella Reddy thinks that it is the HRTO responsibility and obligation to make her positions fully known, to create an argument on her behalf and to present materials that help justify her own request for a deferral and/or dismissal.

It is Applicants position that this is not the case, and that the now alleged former Alto Properties Inc. Property Manager Stella Reddy should not have placed the unrealistic expectations upon HRTO, as it is solely HER responsibility to present, validate and defend her own request for deferral and/or dismissal.

Alto Properties Inc. owner Luigi Liscio and Alto Properties Inc. owner Anthony Liscio state it is an abuse of process to enforce your rights under the law. This only confirms why they hired the now alleged former Alto Properties Inc.

Property Manager Stella Reddy back in June 2016.

This explains why they have hidden behind the curtain as the puppet masters while encouraging the now alleged former Alto Properties Inc. Property Manager Stella Reddy to do their bidding.

They both have the exact same mentality. The moment you stand up for yourself and enforce you rights under the law. They consider you to be challenging them and you are abusing the system and the process.

Let us also remember that Alto Properties Inc. owner Luigi Liscio also stated in his own words on October 25, 2017 to the Applicants husband that he upset that they had went to the Divisional Court and it “ affected ” him and “ you hit my business! ”

It is pretty obvious that Alto Properties Inc. owner Luigi Liscio and Alto Properties Inc. owner Anthony Liscio have acted in reprisal against the Applicants for many reasons, and them enforcing their rights is one of them..

Alto Properties Inc. owner Luigi Liscio and Alto Properties Inc. owner Anthony Liscio also consider someone enforcing their rights as an abuse of process because it “affected ” them and it “ hit ” their business and the Applicants “ should known better ”.

The HRTO has to realize that practically every email the now alleged former Alto Properties Inc. Property Manager Stella Reddy has ever sent to the Applicants, she has chastised them for their actions in regards to the legal system. She has constantly told them that they have zero chance in Divisional Court and with the HRTO. Why?

Because of people like the Social Justice Tribunals Ontario Member Kevin Lundy who allowed her to get away with her behaviour, lies and words and never dealt with it! It is plain and simple!

Because of people like Alto Properties Inc. owner Luigi Liscio and Alto Properties Inc. owner Anthony Liscio allowed her to lie in the LTB hearing, used racially charged language, heard her use prejudice slurs, watched her own racially motivated actions of harassment, discriminating and acting in a reprisal manner, participated alongside with her, and did nothing about it. It is that plain and simple!

Because of people like her unknown Racist Remarks expert tells her that her racially charged language and prejudice slurs and actions were “ mild ” compared to something she could have said if she was an actual racist and thought like one. Some of the things she heard that could have been said because it was not fit to repeat.

·         a claim or pleading that is clearly unfounded in fact or in law;

It is obvious that the Applicants claims are well founded in facts and in law.

·         conduct that is frivolous, vexatious or intended to delay;

It is also obvious that the Applicants complaints are not conduct on frivolous, vexatious documents or arguments.

·         a claim made, or a proceeding brought or conducted, in bad faith;

There is far more than enough documents and arguments to meet the threshold for the Applicants to get a hearing in front of the HRTO. It appears to be the 3 Respondents that have continuously acted in bad faith

·         the use of procedure that is excessive or unreasonable

It is pretty clear by this time to the HRTO that this hearing is needed and that the documents and 3 Respondents statements prove it.

·           or that causes undue prejudice to another person or

Any undue prejudice to the 3 Respondents will have been brought upon themselves through their own words, actions, documents and the Applicants have no control of that.

·         attempts to defeat the ends of justice, and

As this has absolutely to do with the Divisional Court and the LTB hearing, and the Applicants have not asked for the Divisional Court to stay the proceedings until after the HRTO findings. It is obvious that they are trying to defeat the ends of justice.

As the remedies requested in the LTB and the Divisional are not the same as the HRTO, It is obvious that they are trying to defeat the ends of justice.

As this has absolutely nothing to do with the Divisional Court and the Applicants have not asked for the Divisional Court to stay the proceedings until after the HRTO findings. It is pretty clear that there is no intended to delay on the behalf of the Applicants.

·         an attempt to restrict public participation by any person;

The Applicants position is the more the merrier.

It is also the Applicants position that Alto Properties Inc. owner Luigi Liscio and Alto Properties Inc. owner Anthony Liscio have chosen to forfeit their right to have any place at the table to argue any issues relating to their own request for a deferral and/or dismissal, as they have deliberately not provide a physical copy or digital copy of their authorities, present explanations about their authorities that are so vaguely explained or in some cases lack any type of explanation at all to justify their request for a deferral and/or dismissal that they had requested.

It is the Applicants position that Alto Properties Inc. owner Luigi Liscio and Alto Properties Inc. owner Anthony Liscio have taken it upon themselves to deliberately not present the required documents to collaborate or justify their request for deferral and/or dismissal.

Alto Properties Inc. owner Luigi Liscio and Alto Properties Inc. owner Anthony Liscio willfully and without any threats of reprisal, violence, repercussions or intimidation decided that they were not going to address some issue raised in their request for deferral and/or dismissal that was requested by them in their response.

It appears that Alto Properties Inc. owner Luigi Liscio and Alto Properties Inc. owner Anthony Liscio think that it is the HRTO responsibility and obligation to make their positions fully known, to create an argument on their behalf and to present materials that help justify their own request for a deferral and/or dismissal.

It is Applicants position that this is not the case, and that Alto Properties Inc. owner Luigi Liscio and Alto Properties Inc. owner Anthony Liscio should not have placed these inappropriate expectations upon HRTO, as it is solely THEIR responsibility to present, validate and defend their own request for deferral and/or dismissal.

15

NO REASONABLE PROSPECT OF SUCCESS

Now this argument is probably the most fascinating and far reaching requested of them all.

It is again the Applicants position that Alto Properties Inc. Property Manager Stella Reddy has chosen to forfeit her right to have any place at the table to argue any issues relating to her own request for a deferral and/or dismissal, as she has deliberately not presented any documents or argument to collaborate and justify her request for a deferral and/or dismissal that she has requested.

It is the Applicants position that Alto Properties Inc. Property Manager Stella Reddy has taken it upon herself to not present the required documents to collaborate or justify her request for deferral and/or dismissal.

The now alleged former Alto Properties Inc. Property Manager Stella Reddy willfully and without any threats of reprisal, violence, repercussions or intimidation decided that she was not going to address the issue of deferral and/or dismissal that was requested by her in her response.

It appears that the now alleged former Alto Properties Inc. Property Manager Stella Reddy thinks that it is the HRTO responsibility and obligation to make her positions fully known, or to create an argument on her behalf and to present documents that help justify her own request for a deferral and/or dismissal.

It is Applicants position that this is not the case, and that the now alleged former Alto Properties Inc. Property Manager Stella Reddy should not have placed these inappropriate expectations upon HRTO, as it is solely HER responsibility to present, validate and defend her own request for deferral and/or dismissal.

In the Alto Properties Inc. owner Luigi Liscio and Alto Properties Inc. owner Anthony Liscio response they claim there is no case here for the HRTO?

The Applicants that they are completely perplexed by this request to dismiss due to no prospect of success.

The Applicants and the 3 Respondents know that proving discrimination is a very hard case to prove, that it leans in favor of the 3 Respondents. But if this case was not at least justifiable to be heard, one can only imagine what the threshold must be?

Just with the Applicants original complaint filing on June 04, 2018. The Applicants supplied the HRTO with 148 exhibits.

Of the 148 exhibits, 75 exhibits/50% are the 3 Respondents very own paper work. ( emails, letters, NOE, ect.) One would have to be hard pressed to believe that there is NO REASONABLE PROSPECT OF SUCCESS.

Let us remember the outright lines to the HRTO that have been told…

Example 1 – The Applicants being the only tenants to have a BBQ in the building. Example 2 – NO Tenants are allowed to park in visitor parking,

Example 3 – Applicants did not return the required parking forms Example 4 – Her nephew’s complexion

It is also the Applicants position that Alto Properties Inc. owner Luigi Liscio and Alto Properties Inc. owner Anthony Liscio have chosen to forfeit their right to have any place at the table to argue any issues relating to their own request for a deferral and/or dismissal, as they have deliberately not provide a physical copy or digital copy of their authorities,

present explanations about their authorities that are so vaguely explained or in some cases lack any type of explanation at all to justify their request for a deferral and/or dismissal that they had requested.

It is the Applicants position that Alto Properties Inc. owner Luigi Liscio and Alto Properties Inc. owner Anthony Liscio have taken it upon themselves to deliberately not present the required documents to collaborate or justify their request for deferral and/or dismissal.

Alto Properties Inc. owner Luigi Liscio and Alto Properties Inc. owner Anthony Liscio willfully and without any threats of reprisal, violence, repercussions or intimidation decided that they were not going to address some issue raised in their request for deferral and/or dismissal that was requested by them in their response.

It appears that Alto Properties Inc. owner Luigi Liscio and Alto Properties Inc. owner Anthony Liscio think that it is the HRTO responsibility and obligation to make their positions fully known, to create an argument on their behalf and to present materials that help justify their own request for a deferral and/or dismissal.

It is Applicants position that this is not the case, and that Alto Properties Inc. owner Luigi Liscio and Alto Properties Inc. owner Anthony Liscio should not have placed these inappropriate expectations upon HRTO, as it is solely THEIR responsibility to present, validate and defend their own request for deferral and/or dismissal.

16

DOUBLE RECOVERY

It is again the Applicants position that Alto Properties Inc. Property Manager Stella Reddy has chosen to forfeit her right to have any place at the table to argue any issues relating to her own request for a deferral and/or dismissal, as she has deliberately not presented any documents or argument to collaborate and justify her request for a deferral and/or dismissal that she has requested.

It is the Applicants position that Alto Properties Inc. Property Manager Stella Reddy has taken it upon herself to not present the required documents to collaborate or justify her request for deferral and/or dismissal.

The now alleged former Alto Properties Inc. Property Manager Stella Reddy willfully and without any threats of reprisal, violence, repercussions or intimidation decided that she was not going to address the issue of deferral and/or dismissal that was requested by her in her response.

It appears that the now alleged former Alto Properties Inc. Property Manager Stella Reddy thinks that it is the HRTO responsibility and obligation to make her positions fully known, or to create an argument on her behalf and to present documents that help justify her own request for a deferral and/or dismissal.

It is Applicants position that this is not the case, and that the now alleged former Alto Properties Inc. Property Manager Stella Reddy should not have placed these inappropriate expectations upon HRTO, as it is solely HER responsibility to present, validate and defend her own request for deferral and/or dismissal.

The Applicants are unclear as to why this would be an argument with Alto Properties Inc. owner Luigi Liscio and Alto Properties Inc. owner Anthony Liscio. The Applicants are no requesting any finical remedies from the Divisional Court unlike with the HRTO.

So it seems pretty obvious that the Applicants do not need to address this issue. Despite Alto Properties Inc. owner Luigi Liscio and Alto Properties Inc. owner Anthony Liscio placing it in their response.

The Applicants are not seeking the same remedies or monies in neither the LTB, Divisional Court nor the HRTO.

It is the Applicants position that Alto Properties Inc. owner Luigi Liscio and Alto Properties Inc. owner Anthony Liscio have chosen to forfeit their right to have any place at the table to argue any issues relating to their own request for a deferral and/or dismissal, as they have deliberately not provide a physical copy or digital copy of their authorities, present explanations about their authorities that are so vaguely explained or in some cases lack any type of explanation at all to justify their request for a deferral and/or dismissal that they had requested.

It is the Applicants position that Alto Properties Inc. owner Luigi Liscio and Alto Properties Inc. owner Anthony Liscio have taken it upon themselves to deliberately not present the required documents to collaborate or justify their request for deferral and/or dismissal.

Alto Properties Inc. owner Luigi Liscio and Alto Properties Inc. owner Anthony Liscio willfully and without any threats of reprisal, violence, repercussions or intimidation decided that they were not going to address some issue raised in their request for deferral and/or dismissal that was requested by them in their response.

It appears that Alto Properties Inc. owner Luigi Liscio and Alto Properties Inc. owner Anthony Liscio think that it is the HRTO responsibility and obligation to make their positions fully known, to create an argument on their behalf and to present materials that help justify their own request for a deferral and/or dismissal.

It is Applicants position that this is not the case, and that Alto Properties Inc. owner Luigi Liscio and Alto Properties Inc. owner Anthony Liscio should not have placed these inappropriate expectations upon HRTO, as it is solely THEIR responsibility to present, validate and defend their own request for deferral and/or dismissal.

Summary

The Applicants have changed their position in regards to the behaviour of the now alleged former Alto Properties Inc. Property Manager Stella Reddy. At first the Applicants believed that it was a Obsessive Compulsive Behaviour or OCD.

But after doing this reply, it has become in their opinion that now alleged former Alto Properties Inc. Property Manager Stella Reddy is just a Narcissist

Some of the most common traits of a Narcissist are…

  1. They exaggerate – They will overplay or even lie about events. They share their achievements over and over, they actually become a reality to the person. They believe all the things that they share with others.
  • They are masters manipulators – The narcissist will utilize your weakness to ensure that they get what they want. They will degrade you, using your weaknesses to add more power to their personality.
  • They don’t recognize or accept your feelings – The only thing that counts is how they feel. The narcissist will be sure to bulldoze your emotions to make they feel worthy. A narcissist is only concerned with how they feel. Emotions are driven by their needs and desires.
  • They are arrogant – The narcissist is never wrong. They believe they are entitled to everything. They will brag and step over anything or anyone along their path to get the things they want. Being a narcissist doesn’t allow for the person to have a rational moral compass. They aren’t sensitive to anyone’s feelings.
  • The require constant admiration and adoration – The narcissist needs to be the center of attention. When the attention is no longer available, they will move onto another person. They cannot keep relationships for long because no one can keep them on a golden pedestal. They have difficulties keeping jobs and focusing on school as well because they lose interest quickly.
  • They take advantage of others – The narcissist will take advantage of anything and anyone to suit their needs. This means stepping over anything to reach their level of twisted goals. The narcissist appears to have self- confidence and high self-esteem, but it’s a facade. They are lacking self-worth but compensate it by using others to their best interest.
  • They are envious of others – The narcissist cannot accept anyone better than themselves; therefore, when the attention is on someone else, they get angry. They suffer from severe depression and frustration. They

become enraged. They are envious of anything that doesn’t come to them and their attention.

  • They believe they are superior – They believe they are above anyone. Their grandiose attitude is overwhelming. They do no wrong. When something doesn’t go their way, it’s because of someone else who messed up. There is no way to rationalize with their behavior.

In the Applicants opinion there is no shortage of these mentioned traits by the now the alleged former Alto Properties Inc. Property Manager Stella Reddy throughout this reply.

This Narcissist behaviour now sudden shines a whole new light on everything she has done in regards to her own racially motivated actions of harassment, discriminating and acting in a reprisal manner against the Applicants.

It explains away any remaining questions as to why she would use such racially charged language, prejudice slurs in a public forum without fear.

Alto Properties Inc. owner Luigi Liscio and Alto Properties Inc. owner Anthony have allowed and enabled the now alleged former Alto Properties Inc. Property Manager Stella Reddy to retaliate against the Applicants in a racist and discriminatory manner despite it being brought to their attention on different occasions by the Applicants.

Everyone is a bit of a Narcissist in their own little ways, but the problem with people like the now alleged former Alto Properties Inc. Property Manager Stella Reddy. Is that when they do something wrong and they are not corrected or they are encouraged to continue, they take it to a level that a normal behaviour is no longer considered.

There is no doubt that the now alleged former Alto Properties Inc. Property Manager Stella Reddy is aware of her behaviour.

  • She joyfully takes responsible for getting the Applicants evicted.
  • She gladly admits that she made racially charge comments.
  • She enjoys scolding and lectures the Applicants about her knowledge of the system.
  • She eagerly continues to lie to the HRTO about the same things even after being caught.
  • She proudly can’t wait to get in front of the HRTO to justify her actions.
  • She happily inconvenience the Applicants every chance she could.

Another example of her narcissist behaviour is when the now alleged former Alto Properties Inc. Property Manager Stella Reddy thought everything was going her way between June 2016 to July 2018.

During this time not once did the now alleged former Alto Properties Inc. Property Manager Stella Reddy complain about her many health issues.

She did not have health issues when …

she was made the pattern of her making the Applicants sit around, waiting 3 times for her, and she never bothered to show up without warning.

She did not have health issues when …

when she was building the 3 Respondents provoked case to have the evicted.

She did not have health issues when…

she was throwing away the key to their unit to justify her illegal N5 to get them evicted.

She did not have health issues when…

she was in front of Social Justice Tribunal Member Kevin Lundy of September 26, 2017, lying.

She did not have health issues when…

she refused the Applicants parking at the building, but at the same time gave the all-white 306 tenant that same privilege she refused the interracial Applicants.

But as soon as the Applicants file their HRTO complaints against her and she reads the basis of it. Suddenly the now alleged former Alto Properties Inc. Property Manager Stella Reddy has become plagued by so many health issues it is hard to keep up.

It appears to the Applicants that there might be a connecting to these sudden health issues and the filing of their Application on June 04, 2018 against the now alleged former Alto Properties Inc. Property Manager Stella Reddy?

If this connection is true, it would again be another classic symptom of a Narcissist doing what they do best, and that is try and manipulate the situation.

By what it appears again to be the now alleged former Alto Properties Inc. Property Manager Stella Reddy trying to gain some form of sympathy from the HRTO.

The Applicants also take the position that the now alleged former Alto Properties Inc. Property Manager Stella Reddy alleged medical issues are not relevant to their HRTO complaints against her.

Based on the facts that at the time of her racially motivated actions of harassment, discriminating and acting in a reprisal manner. She was of solid mind and good health, and what happened after the fact is not relevant to her behaviour pre-HRTO complaints.

Her health issues that appeared only after the pre-HRTO complaints no matter how fake, or serious they are. Are irrelevant as a defence for the now alleged former Alto Properties Inc. Property Manager Stella Reddy.

It appears to the Applicants that the now alleged former Alto Properties Inc. Property Manager Stella Reddy is planning to try and use her medical issues as some way to rationalize all of her pre-HRTO complants, racially motivated actions of harassment, discriminating and acting in a reprisal manner.

Again it is the opinion of the Applicants, as they are not doctors they cannot say with certainty about her being a Narcissist, but as the old saying goes.

If it walks like a duck, sounds like a duck, acts like a duck and looks like a duck… it’s probably a duck.

In regards to Alto Properties Inc. owner Luigi Liscio and Alto Properties Inc. owner Anthony Liscio who have heard and seen the racially charged language and actions of that they’re now alleged former Alto Properties Inc. Property Manager Stella Reddy in person at the LTB hearing.

They have continue to rally behind her, united in their fight in the HRTO and Divisional Court to have the Applicants removed from the building.

They have read all the documents provided by the Applicants, they have seen the huge amount of outright lies that their now alleged former Alto Properties Inc. Property Manager Stella Reddy has been telling to the HRTO and probably themselves.

And still they continue to sit on their hands, ignore the facts in their joint effort to fight and spend more money in the HRTO and Divisional Court to have the Applicants removed from the building. Because Alto Properties Inc. owner Luigi Liscio is upset that the Applicants called them out for their behaviour and for enforced their rights to appeal in Divisional Court that it “ affected ” him and “ you hit my business ” and they “ should known better ”.

There can be no other determination other than Alto Properties Inc. owner Luigi Liscio and Alto Properties Inc. owner Anthony Liscio have acted in a reprisal manner against the Applicants.

By Alto Properties Inc. owner Luigi Liscio and Alto Properties Inc. owner Anthony Liscio getting the Applicants evicted or to move out. They stand to gain a 63% profit in rent from their unit. $1106 verses $1750

Alto Properties Inc. owner Luigi Liscio and Alto Properties Inc. owner Anthony Liscio retaliated because the

“ Black ” called them out for their lack of actions and concerns about by the now alleged former Alto Properties Inc. Property Manager Stella Reddy racially motivated actions of harassment, discriminating and acting in a reprisal manner.

Alto Properties Inc. owner Luigi Liscio and Alto Properties Inc. owner Anthony Liscio retaliated because the Applicants enforced their rights under the law to appeal the illegal eviction order made by the Social Justice Tribunals Ontario Member Kevin Lundy

Alto Properties Inc. owner Luigi Liscio and Alto Properties Inc. owner Anthony Liscio retaliated because the Applicants called them out to the HRTO for their participation with now alleged former Alto Properties Inc. Property Manager Stella Reddy in the continuous harassment and inconveniencing of them.

The list at this point is almost endless, and at some point the Applicants have to stop addressing these endless amounts of misquotes facts, lies and obvious illegal actions of the 3 Respondents.

There as so many inconsistences that could be addressed that it would take the Applicants months just to sit down and cross reference, rebuke and show every lie and misquoted fact and questionable actions on the behalf of the 3 Respondents. It just is not realistic nor is it logical to think that they need or can do it at this time.

The Applicant would challenge any of the 3 Respondents to prove with where the Applicants have lied or mislead the HRTO?

To continue down this long written road of going through their current paper work and that of the remaining paper work the Applicants have. It would only continue to confirm that when the 3 Respondents were called out on it by the Applicants in their letters, the 3 Respondents decided to retaliate against the “ Black ”Applicant and her family by using their positions with Alto Properties Inc. to achieve it. The whole time encouraging and enabling each other and trying to build a case against them so they could have them removed for multiple benefits.

There really is no need at this time for the Applicants to continue addressing the 3 Respondents behaviour. The HRTO

has the 3 Respondents own;

  • Words
  • Documents
  • Videos
  • behaviour

to help them make a finding against them.

The Applicants have made it very obvious to the HRTO and anyone who reads this file. That despite of all the

  • Documents
    • Emails
    • Videos
    • Pictures
  • Obvious Lies
    • Racially Charged Language
    • Prejudice Slurs
    • October 25, 2017 Conversation
    • Harassment
    • Racist Motivated Behaviour
    • Discrimination
    • Intentional Inconveniencing
    • Illegal N5’s

The now alleged former Alto Properties Inc. Property Manager Stella Reddy was their – GO TO PERSON for Alto Properties Inc. owner Luigi Liscio and Alto Properties Inc. owner Anthony Liscio.

The Applicants reply, without any doubt shows that despite any words or lack of words the 3 Respondents try and use, to try explain away their prejudice and discriminatory behaviour towards the Applicants.

The reality of this situation for them is that they have provided no visual case law, presented no acceptable arguments or explanations to justify why everyone was in NOT in cahoots in their attempts to have the applicants removed from the building.

It is pretty clear and pretty obvious that the now alleged former Alto Properties Inc. Property Manager Stella Reddy is far from being “ obvious ” or “ Naive ” as it has been claimed.

She freely makes narcissist statements like “ I could have said worse, ”

She has NEVER shown a touch remorse for her behaviour or even hinted at a apologizing,

She brags how “ no will give a shit ” racially charged language, prejudice slurs and her own racially motivated actions She makes false claims “ I see people as people. To me it don’t matter what they look like, ” yet they has open compared, referred to and insulted the Applicant and her own nephew based on their complexion.

She continues to lie to the HRTO, despite being unquestionable caught.

The HRTO needs to dismiss the 3 Respondents request for deferral and/or dismissal. Thank you.

Kory, Allison, Kniighetti and Eexii – Read

The Applicants wish to enforce their rights to add to this Reply as needed or requested.

LATE

ENTRYS

In regards to any issues of the father, daughter and son Applications moving forward without the mother.

“ [29] In my view, this is not a case in which deferral is appropriate. The factual allegations at issue in the PSA proceedings form only a part of the allegations at issue in this Application. Based on the information filed, it  appears to me that the tribunal dealing with the PSA proceedings is narrowly focused, and although that tribunal may have the authority to apply the Code, it is not clear that it would be necessary to do so in dealing with the allegations noted and issues identified in the initiating document. The application of the Code could not be raised by the applicant in those proceedings, as she is not a party. Finally, the PSA hearing date is set for October 14 and 15, 2010; there is only the smallest risk of inconsistent factual findings. ”

In regards to any issues of defer and inconsistent findings.

“ [14] In considering the factors of the subject matter of the other proceeding, the nature of the other proceeding, the types of remedies available in the other proceeding, and whether it would be fair overall to defer having regard to the status of each proceeding and the steps that have been taken to pursue them, I find that it is not appropriate to defer consideration of the Application at this time. In the particular circumstances of this case, the most fair, just and expeditious outcome is to proceed with this Application. ”

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